Season 8 · Episode 14
What you need to know about beneficial ownership and customer due diligence in 2025
December 4, 202421m 56s
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Show Notes
Saved by the bell? Millions of American businesses faced a January 1 deadline to register their beneficial owners with the Financial Crimes Enforcement Network — until a federal judge issued a preliminary injunction yesterday stopping FinCEN from enforcing the deadline. On the latest episode of the ABA Banking Journal Podcast — sponsored by TransUnion — ABA experts Heather Trew and Jonathan Blum discuss:
- What bankers and their business clients need to know about the preliminary injunction and its provisions.
- How the preliminary injunction does not affect financial institutions' customer due diligence requirements — even if businesses are not required to report their beneficial ownership information to FinCEN, banks are still obliged to collect it from clients as part of CDD.
- Potential ramifications for AML/BSA activities if the Corporate Transparency Act that authorized the BOI registry is found to be unconstitutional.
- How this and other cases challenging the BOI registry may shake out, as well as the range of views on Capitol Hill on where to go from here.
- How ABA is engaging with both the current Congress and administration, and will advocate with the next Congress and incoming presidential administration, on these issues.