Harris Beach attorney Constantine P. Lizas recently presented a webinar on the Corporate Transparency Act’s Beneficial Ownership Information Rule on behalf of RiskScout, a fintech – financial technology company – providing financial institutions with customer due diligence solutions.
The webinar, “Navigating the Corporate Transparency Act: The Final BOI Rule,” is still available for viewing. In addition, Constantine answered several questions on the CTA and the BOI rule.
Beginning in January, reporting companies, including LLCs, are required to furnish the names of individuals who own a 25% ownership interest or more in the company to the U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN). In addition, reporting companies must also supply a list of individuals with substantial control of the company. These individuals can include the CEO, the CFO, board members, and others. Reporting companies created after this year will also have to report the company applicant.
Additionally, existing rules also require legal entities to supply ownership and control information directly to financial institutions when opening new accounts. Financial institutions, with the permission of the customer, will be able to query FinCEN for beneficial ownership information.
Constantine advises financial services clients on Bank Secrecy Act/Anti-Money Laundering (BSA/AML), digital currency, blockchain, and other banking regulatory issues before the federal banking agencies and FinCEN. He formerly served as lead counsel for the FDIC on BSA/AML matters and as a trial attorney at the U.S. Department of Justice working in the Money Laundering and Asset Recovery Section.