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Nonprofits and beneficial ownership?

Answered by: 

Question: 
If our customer is a nonprofit organization, do we complete beneficial ownership certification?
Answer: 

That depends on whether the "organization" is a legal entity. If it is a nonprofit corporation or nonprofit LLC, yes, you will need to obtain a beneficial ownership certification from the entity, but you will only need to have information on the "control individual," because nonprofit legal entities typically do not have owners, and because the regulation, in ยงย 1010.230(e)(3)(ii), indicates you only need to have the "control prong" of the requirement completed.

If the "organization" is not a legal entity, the beneficial ownership requirement simply does not apply.

Just be sure you check to see whether the organization is a legal entity first.

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Learn more about Deborah Crawford webinar 25 Errors on Beneficial Ownership Certification of Legal Entities

First published on 10/11/2020

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