The Association has filed it Beneficial Ownership Information with FinCEN. Beneficial ownership information refers to identifying information about the individuals who directly or indirectly own or control a company.  FinCEN is a bureau of the U.S. Department of the Treasury authorized in 2021 when Congress passed the Corporate Transparency Act. 

FinCEN’s mission is to safeguard the financial system from illicit activity, counter money laundering and the financing of terrorism, and promote national security through strategic use of financial authorities and the collection, analysis, and dissemination of financial intelligence.  This law creates a new beneficial ownership information reporting requirement as part of the U.S. government’s efforts to make it harder for bad actors to hide or benefit from their ill-gotten gains through shell companies or other opaque ownership structures.

In accordance with the Corporate Transparency Act, FinCEN may permit access to beneficial ownership information to:

• Federal agencies engaged in national security, intelligence, or law enforcement activity;

• State, local, and Tribal law enforcement agencies with court authorization;

• Officials at the Department of the Treasury;

• Foreign law enforcement agencies, judges, prosecutors, and other authorities that submit a request through a U.S. Federal agency to obtain beneficial ownership information for authorized activities related to national security, intelligence, and law enforcement;

• Financial institutions with customer due diligence requirements under applicable law (in order to facilitate compliance with those requirements); and

• Federal functional regulators or other appropriate regulatory agencies that supervise or assess financial institutions with access to beneficial ownership information (in order to supervise such financial institutions’ compliance with customer due diligence requirements).

Beneficial ownership information reported to FinCEN is stored in a secure, non-public database using rigorous information security methods and controls typically used in the Federal government to protect non-classified yet sensitive information systems at the highest security level.