Determining a Legal Entity for Purposes of Beneficial Ownership

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Recorded Webinar Includes

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FinCEN's beneficial ownership rules, effective May 11, 2018, require your institution to maintain written procedures to identify and verify the beneficial owners of legal entities that open accounts at your institution. The new rules specifically define what types of businesses are considered legal entities and outline a two-prong test for determining beneficial ownership. This webinar will clearly explain, with examples, which entities are covered by the rules and define the specific documents needed to properly identify and verify beneficial owners.

Recorded Friday, July 6, 2018

Attendance certificate provided to self-report CE credits.


  • Learn what constitutes sufficient due diligence under the new rules
  • Explanation of each type of legal entity covered by the new rules and practical examples of the information needed to identify and verify them
  • Required tests to determine beneficial ownership and examples of the information needed to identify and verify them
  • When can you rely on information and documentation already contained in your records?
  • Sample provisions to add to your Certification of Beneficial Ownership to reduce your administrative burden on automatically renewable accounts

    • Official Certification of Beneficial Owner[s] form published by FinCEN
    • Additional provisions to the Certification of Beneficial Owner[s] form for automatically renewable accounts
    • Recent FAQs published by FinCEN
    • Employee training log
    • Quiz you can administer to measure staff learning and a separate answer key


This informative session will be useful to all deposit operations personnel, account service representatives, compliance personnel, auditors, attorneys, and managers.


NOTE:  All materials are subject to copyright. Transmission, retransmission, or republishing of any webinar to other institutions or those not employed by your financial institution is prohibited. Print materials may be copied for eligible participants only.


Spencer Fane LLP
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