FinCEN Small Entity BOI Disclosure Guidance

The Financial Crimes Enforcement Network (FinCEN) published a small entity compliance guide today that provides an overview of the requirements regarding access to beneficial ownership information (BOI) by small entities – in particular, small financial institutions authorized to access BOI.  

Under the Access Rule, issued in December 2023, BOI reported to FinCEN is confidential, must be protected, and may be disclosed only to certain authorized Federal agencies; state, local, tribal, and foreign governments; and financial institutions. 

The guide includes sections summarizing the Access Rule’s requirements that pertain to small financial institutions’ access to BOI.   In order to access BOI, financial institutions will be required to develop and implement administrative, technical, and physical safeguards that are designed to protect the security, confidentiality, and integrity of BOI.

As a reminder, FinCEN is now accepting BOI reports. Learn more about reporting requirements and filing deadlines at https://www.fincen.gov/boi.

Small Entity Compliance Guide for Beneficial Ownership Information Access and Safeguards Requirements:https://www.fincen.gov/sites/default/files/shared/BOI_Access_and_Safeguards_SECG_508C.pdf