The following guidance has recently been issued:
Summary: This letter and its attachment clarify that the issuance of the Access Rule does not create a new regulatory requirement for banking organizations to access beneficial ownership information (BOI) from the Financial Crimes Enforcement Network’s (FinCEN) Beneficial Ownership Information Technology System or a supervisory expectation that they do so. Therefore, the Access Rule does not necessitate changes to Bank Secrecy Act (BSA)/anti-money laundering (AML) compliance programs designed to comply with the existing Customer Due Diligence rule and other existing BSA requirements, such as customer identification program requirements and suspicious activity reporting.