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25 Critical Errors on Beneficial Ownership

Recorded on December 05, 2018

During the process of getting ready for beneficial ownership there were FAQs, Exam Procedures and Regulations issued. In this maze of decisions that were made by FinCEN, where could you possibly go wrong? Everywhere! From date account was opened to renewals, there is a great deal of confusion on beneficial ownership.


  • How to fill out the form-what is going wrong
  • LEIs are not NAICS or State Charter Numbers
  • Who is a controlling person? Who is an owner?
  • Entities do not have their place in beneficial ownership boxes
  • What is an address? You might be surprised what we are seeing on the form
  • Drilling down on business accounts
  • Documenting your exemptions or exclusions
  • What renewals are out? When does a renewal stay in?
  • Intermediaries as owners of accounts
  • Trustees as owners of accounts
  • Verbal and written recertifications
  • What still is unresolved?
  • And much more

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