Davis Polk partner Dan Stipano was quoted in MoneyLaundering.com on FinCEN’s new national beneficial ownership database, which will allow banks and other financial institutions to have access to beneficial ownership information but only in narrowly defined circumstances. “[FinCEN’s] discretion is limited by the statute, so they couldn’t really make access much broader than they did,” Dan explained. He noted that banks “can see if the information in the registry is consistent with information they’ve obtained from their customer – and I think that’s basically it.”

FinCEN Rolls Out ‘Access Rule’ for Beneficial Ownership Database,” MoneyLaundering.com (December 15, 2022) (subscription required)