Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a final rule regarding when a reporting company may report an entity’s FinCEN identifier instead of information about an individual beneficial owner.
A FinCEN identifier is a unique number that FinCEN will issue upon request after receiving the required information. Although there is no requirement to obtain a FinCEN identifier, doing so can simplify the reporting process and allow entities or individuals to provide the required identifying information directly to FinCEN.
The final rule, which amends FinCEN’s final Beneficial Ownership Information (BOI) Reporting Rule, specifically responds to commenter concerns that the reporting of entity FinCEN identifiers could obscure the identities of beneficial owners in a manner that might result in greater secrecy or incomplete or misleading disclosures.
The final rule provides clear criteria for a company to report an intermediate entity’s FinCEN identifier instead of information about the individual beneficial owner. The rule goes into effect on Jan. 1 to align with the effective date of the BOI Reporting Rule.