What you need to know about beneficial ownership and customer due diligence in 2025

ABA Banking Journal Podcast

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.

This episode is presented by TransUnion.