Financial institutions play a crucial role in combating financial crimes such as money laundering and terrorist financing. To facilitate this effort, the Financial Crimes Enforcement Network (FinCEN) requires certain institutions to file Bank Secrecy Act (BSA) reports, including the FinCEN Report 111, also known as the FinCEN BOI (Beneficial Ownership Information) Form. This form aims to enhance transparency in financial transactions by disclosing beneficial ownership information of legal entity customers. Navigating through these forms can be daunting, but fear not, as we present a step-by-step guide to completing FinCEN BOI Forms.
Step 1: Understand the Requirement Before diving into the form, it’s crucial to understand who needs to file it and why. Generally, covered financial institutions such as banks, credit unions, and broker-dealers are required to collect and report beneficial ownership information when opening accounts for legal entity customers. Legal entities include corporations, limited liability companies (LLCs), partnerships, and other similar structures.
Step 2: Gather Required Information Next, gather all necessary information about the legal entity customer and its beneficial owners. This typically includes personal information such as names, addresses, dates of birth, social security numbers, and identification numbers. Additionally, you’ll need to identify the individuals who directly or indirectly own 25% or more of the legal entity and those who have significant control over it.
Step 3: Start the Form Once you have the required information, begin filling out the FinCEN BOI Form. The form is available electronically on the FinCEN website. Make sure you have the most recent version of the form to avoid any discrepancies.
Step 4: Provide Legal Entity Information The first section of the form requires details about the legal entity itself. This includes its name, address, incorporation details, and tax identification number (TIN). Ensure accuracy when providing this information to prevent any delays or errors in processing.
Step 5: Identify Beneficial Owners In the subsequent sections, identify each beneficial owner of the legal entity. For each owner, enter their full legal name, address, date of birth, TIN or passport number, and the percentage of ownership or control they hold. Remember to include individuals who meet the 25% ownership threshold or exercise significant control over the entity.
Step 6: Provide Certification After completing the necessary sections, certify the accuracy of the information provided. This certification confirms that the information is true and complete to the best of your knowledge.
Step 7: Review and Submit Before submitting the form, review all information for accuracy and completeness. Double-check names, addresses, and other details to ensure there are no errors. Once satisfied, submit the form electronically through the FinCEN BSA E-Filing System.
Step 8: Maintain Records After submission, maintain a copy of the completed form and all supporting documentation for your records. These records may be subject to inspection by regulatory authorities, so it’s essential to keep them organized and accessible.
