On September 7, 2018, the Financial Crimes Enforcement Network (FinCEN) granted exceptive relief from the beneficial owner rule’s requirements to identify and verify the beneficial ownership of the legal entity customer for the following account types:
- Certificate of Deposit rollovers;
- Loan renewals, modifications, and extensions that do not require underwriting review and approval;
Commercial line of credit or credit card account renewals, modifications, or extensions that do not require underwriting review and approval; and - Safe deposit box renewals.
Financial institutions are no longer required to collect beneficial owner information for these accounts at each rollover, renewal, extension, or modification for accounts that were opened after May 11, 2018. This relief also applies to those accounts that were opened before May 11, 2018 and are renewed or rolled over after May 11, 2018. However, financial institutions are still required to collect beneficial owner information when these accounts are initially opened and to fully comply with all other applicable anti-money laundering requirements.
Link to the ruling: https://www.fincen.gov/resources/statutes-regulations/administrative-rulings/exceptive-relief-beneficial-ownership