Beneficial Owner Certification

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Question:

Regarding a Beneficial Owner Certification: ABC, LLC (Borrower) is 100% owned by DEF, Inc. DEF, Inc. is 33.33% owned by 3 individuals. Would I need to list the individuals as having 25% or more ownership on the certification, even though they are not owners of ABC, LLC?

Answer:

Yes. You are required to identify all direct or indirect beneficial owners with more than 25% ownership interest in your customer plus one control person who may or may not be one of the three beneficial owners of ABC LLC.

FinCEN addresses this scenario in Question #3 of its April 2018 Beneficial Ownership FAQs.