The Financial Crimes Enforcement Network (FinCEN) issued an administrative ruling providing a 90-day exemption from the requirements of the Beneficial Ownership Rule for certain products and services that automatically renew or rollover (e.g., a Certificate of Deposit) that were established before the mandatory compliance date of May 11, 2018. FinCEN indicated that it wanted to use this time to determine what, if any, additional relief should be provided for these products and services because financial institutions may not have considered these products to be new accounts, and financial institutions have expressed concern about their ability to comply with the Beneficial Ownership Rule.
The exemption begins retroactively to May 11, 2018 and expires on August 9, 2018.