On November 7, 2023, FinCEN issued a final rule that specifies the circumstances in which a reporting company may report an entity’s FinCEN identifier in lieu of information about an individual beneficial owner. A FinCEN identifier is a unique number that FinCEN will issue upon request after receiving required information, which can simplify the reporting process.
The final rule amends FinCEN’s final Beneficial Ownership Information (BOI) Reporting Rule and provides clear criteria that must be met in order for a reporting company to report an intermediate entity’s FinCEN identifier in lieu of information about the individual beneficial owner. The amendment was made in response to commenter concerns that the reporting of entity FinCEN identifiers could obscure the identities of beneficial owners in a manner that might result in greater secrecy or incomplete or misleading disclosures.
The final rule is effective on January 1, 2024, to align with the effective date of the BOI Reporting Rule.
Read FinCEN’s press release here.
The final rule can be found here.