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Financial Institution Letter
Bank Secrecy Act Interagency Guidance on Beneficial Ownership
Summary: The FDIC, the other federal banking agencies (FBAs), the Financial Crimes Enforcement Network (FinCEN), and the Securities and Exchange Commission (SEC) – in consultation with staff of the Commodity Futures Trading Commission (CFTC) – are issuing the attached guidance regarding beneficial ownership information.

  • This guidance clarifies and consolidates existing regulatory expectations for obtaining beneficial ownership information as part of the customer due diligence (CDD) and enhanced due diligence (EDD) processes related to certain accounts and customer relationships.
  • A depository institution's CDD/EDD processes should be developed to identify customers who pose heightened money laundering or terrorist financing risks, and should be enhanced in accordance with the institution's assessment of those risks. Conducting appropriate CDD assists an institution in identifying, detecting and evaluating unusual or suspicious activity.
  • A financial institution should establish and maintain CDD procedures that are reasonably designed to identify and verify the identity of beneficial owners of an account, as appropriate.
  • Beneficial ownership information regarding account relationships provides another tool for depository institutions to better understand and address money laundering and terrorist financing risks, protect themselves from criminal activity, and assist law enforcement with investigations and prosecutions.
  • A depository institution may consider implementing beneficial ownership policies and procedures on an enterprise-wide basis.

FDIC-Supervised Banks (Commercial and Savings)

Suggested Routing:
Chief Executive Officer
BSA Compliance Office

FDIC Financial Institution Letters (FILs) may be accessed from the FDIC's Web site at:

To receive FILs electronically, please visit .

Paper copies of FDIC FILs may be obtained through the FDIC's Public Information Center,

3501 N. Fairfax Drive, Room E 1002, Arlington, VA 22226 (1-877-275-3342 or 703-562-2200).

Additional Related Topics:

  • Bank Secrecy Act/Anti-Money Laundering Programs
Last Updated: March 5, 2010