Regulatory Alerts2018-05-11
Premium Finance Cash Refunds and Beneficial Ownership Requirements for Legal Entity Customers
The Financial Crimes Enforcement Network (FinCEN) issued this ruling to grant exceptive relief to covered financial institutions from the Beneficial Ownership Rule requirements for premium finance lending products that involve cash refunds. FinCEN determined that the structural characteristics of these transactions and the low risk of money laundering associated with automated cash refunds do not warrant the burden of collecting and verifying beneficial ownership information. Financial institutions remain obligated to comply with all other Bank Secrecy Act requirements, including the filing of suspicious activity reports for any potentially illicit transactions.
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