Board of Governors of the Federal Reserve System

The Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the Financial Crimes Enforcement Network (FinCEN), the National Credit Union Administration, and the Office of the Comptroller of the Currency (collectively, the agencies) are issuing an interagency statement to clarify banking organizations’ obligations following the issuance of FinCEN’s final rule regarding access by authorized recipients to beneficial ownership information (BOI) that will be reported to FinCEN (the “Access Rule”), pursuant to section 6403 of the Corporate Transparency Act (CTA).

The interagency statement clarifies that the issuance of the Access Rule does not create a new regulatory requirement for banking organizations to access BOI from FinCEN’s Beneficial Ownership Information Technology (BO IT) System or a supervisory expectation that they do so. Therefore, the Access Rule does not necessitate changes to Bank Secrecy Act (BSA) / anti-money laundering (AML) compliance programs designed to comply with the existing Customer Due Diligence rule and other existing BSA requirements, such as customer identification program requirements and suspicious activity reporting. However, any access to and use of BOI obtained from the BO IT System must comply with the requirements of the CTA and the Access Rule.

Reserve Banks are asked to distribute this letter to the supervised banking organizations in their districts and to appropriate supervisory staff. In addition, banking organizations may send questions via the Board’s public website.¹

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