In February 2024, FinCEN published the Small Entity Compliance Guide for Beneficial Ownership Information Access and Safeguards Requirements intended to help small entities comply with the Beneficial Ownership Information Access and Safeguards Rule. The Compliance Guide provides an overview of the Beneficial Ownership Information Access and Safeguards Rule requirements for small entities that obtain BOI from FinCEN.
The Small Entity Compliance Guide provides guidance on the use of BOI expanding on the authorized use of BOI obtained from FinCEN and limits on re-disclosure of BOI by financial institutions. It also provides further guidance on security and confidentiality requirements including geographic restrictions, information procedures, notification of information demands, customer consent, and certification. Finally, the Guidance expands on the administration of requests and violations.
The Small Entity Guidance can be found here.