SR 23-11

In view of the finalization of the „access rule“ as regards access to FinCEN’s database on beneficial ownership information (BOI) (EventID 24631), several U.S. banking regulators, including the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the National Credit Union Administration, and the Office of the Comptroller of the Currency, as well as FinCEN itself have published a joint Interagency Statement for Banks on the Issuance of the Beneficial Ownership Information Access Rule. In this statement, the regulators and FinCEN emphasize that the new rule by itself does not impose any new requirements on banks. Banks are not required to access BOI from FinCEN if they feel comfortable to otherwise fulfill their due diligence and Bank Secrecy obligations. However, if they do so, they must ensure to comply with the access rule, including having efficient safeguards to protect the retrieved information and providing adequate staff training for handling BOI information.