Davis Polk partner Dan Stipano was quoted in MoneyLaundering.com on FinCEN’s proposed path for building a national database of corporate owners, a task mandated by the Corporate Transparency Act. Dan noted, “It is clear that FinCEN intends to cast a broad net – in particular, the definition of ‘beneficial owner’ is much broader than in the existing [Customer Due Diligence] CDD rule and will require many more individuals to provide their information.” He added that some entities currently covered by the CDD rule would not be covered by the proposal and that “this lack of alignment makes it likely that FinCEN will make substantial changes to the CDD rule when it issues conforming amendments.”

“With Congressional Deadlines Looming, FinCEN Charts Path for Ownership Database,” MoneyLaundering.com (December 7, 2021) (subscription required)

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