As the Financial Crimes Enforcement Network prepares to create a new beneficial ownership registry, ABA made several recommendations that should guide the agency as it develops the database—including that FinCEN ensure usability and ease of access for reporting companies, law enforcement and financial institutions.
In a comment letter to FinCEN today, ABA said it supports the creation of the registry and that reporting should build on existing requirements in FinCEN’s customer due diligence rule. The association also recommended that FinCEN take steps to verify the information submitted by reporting companies; that definitions for terms such as “beneficial ownership” be clear and simple; and that FinCEN take appropriate steps to notify reporting companies about the requirements.
ABA also emphasized that banks should have simple and comprehensive access to the registry to support their anti-money laundering efforts and that reporting companies should submit information electronically to avoid errors that can occur when transcribing data from paper forms.
