2021 Ohio Bankers Day

CTA KEY REQUIREMENTS

Develop a Beneficial Ownership IT System  FinCEN is charged with establishing reporting requirements, safeguarding the data, and governing access protocols.  FinCEN will amend its existing Customer Due Diligence (CDD) Rule to account for the new reporting regime.

CTA KEY REQUIREMENTS (continued)

FinCEN will work with federal agencies, states, tribes, and private industry to: 1. Educate and assist potential reporting companies with reporting obligations and exclusions; 2. Ensure adequate information is being reported accurately; 3. Safeguard the reported information in a secure and confidential database; 4. Provide for appropriate audits and inspections, and 5. Govern access to the data.