Beneficial Ownership Information Reporting

ALERT [Updated March 26, 2025]: All entities created in the United States — including those previously known as “domestic reporting companies” — and their beneficial owners are now exempt from the requirement to report beneficial ownership information to FinCEN. Existing foreign companies that must report their beneficial ownership information have at least an additional 30 days from March 26, 2025—until April 25, 2025, for most companies—to do so. For more information, see press release and alert.

Today, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued orders identifying three Mexico-based financial institutions—CIBanco S.A., Institution de Banca Multiple (CIBanco), Intercam Banco S.A., Institución de Banca Multiple (Intercam), and Vector Casa de Bolsa, S.A. de C.V. (Vector)—as being of primary money laundering concern in connection with illicit opioid trafficking, and prohibit, respectively, certain transmittals of funds involving CIBanco, Intercam, and Vector.

This week, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) launched a new series entitled “Combating and Obstructing Money Movements Associated with Narcotics and Drug Trafficking Organizations” (COMMAND).

WASHINGTON—To provide banks with greater flexibility in fulfilling compliance obligations, today, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an order permitting banks to collect Tax Identification Number (TIN) information from a third party rather than from the bank’s customer.