[WSBARP] FinCEN Reporting of BOI

[Katie Smith Patel]

The purpose is to close a long-standing gap of who beneficially owns entities for anti-money laundering purposes.  When setting up entities in states, there is no universal beneficial owner blank required to be filled, and this has long been a gap crippling the ability to follow dirty money back to ultimate beneficial owners.  Up until now, FinCEN has collected suspicious activity report (SAR) filings that are secretly filed by financial institutions any time a bank has any activity or account owner that raises suspicion of illegal activity.  All of these reports are gathered into a database searchable by law enforcement for investigative purposes.  However, the dots can’t be connected from an individual to an entity without some statement of who beneficially owns each entity.  So my guess is this information will supplement the SAR information to connect any entity SARs back to individuals and vice versa.

The US is a member of FATF (Financial Action Task Force) but even at FATF’s most recent assessment of the US’s anti-money laundering and counter-terrorist financing measures, the US was only fully compliant on 9 out of 40 recommendations.  One of the “not compliant” ratings (the worst rating level) was entity beneficial ownership (recommendation 24).

https://www.fatf-gafi.org/en/publications/Mutualevaluations/Fur-united-states-2020.html

I guess the US no longer wants to appear hypocritical in this regard.

Katie Patel
Paraclete Estate Planning, LLC
(541) 499-9085 (direct)
112 Genessee Street
Medford, OR 97504


From: wsbarp-bounces at lists.wsbarppt.com <wsbarp-bounces at lists.wsbarppt.com> On Behalf Of Roger Hawkes
Sent: Wednesday, January 17, 2024 11:43 AM
To: WSBA Real Property Listserv <wsbarp at lists.wsbarppt.com>
Subject: Re: [WSBARP] FinCEN Reporting of BOI

What is their objective?  Why do millions of people have to spend three minutes of their time to do this?

From: wsbarp-bounces at lists.wsbarppt.com<mailto:wsbarp-bounces at lists.wsbarppt.com> <wsbarp-bounces at lists.wsbarppt.com<mailto:wsbarp-bounces at lists.wsbarppt.com>> On Behalf Of Brent Williams-Ruth
Sent: Wednesday, January 17, 2024 10:54 AM
To: WSBA Probate & Trust Listserv <WSBAPT at lists.wsbarppt.com<mailto:WSBAPT at lists.wsbarppt.com>>; WSBA Real Property Listserv <wsbarp at lists.wsbarppt.com<mailto:wsbarp at lists.wsbarppt.com>>; Solo and Small Practice Section <solo-and-small-practice-section at list.wsba.org<mailto:solo-and-small-practice-section at list.wsba.org>>
Subject: [WSBARP] FinCEN Reporting of BOI

Greetings List Members -

I just wanted to share my experience with filing the Beneficial Ownership Information data through the Financial Crimes Enforcement Network (FinCEN).

It was super easy. Honestly, the most difficult part was remembering that Treasury website (like the IRS) only allow submissions during business hours. I tried and failed 3 times to file on Sunday. Today, it took me only the one time and was over in about 3 minutes.

What you will need:
1) Corporate name of your entity
2) Tax ID
3) All beneficial owners (in my case, a sole member PLLC so it was easy)
4) a government issued ID as a PDF (note, the file name cannot have spaces)

Super easy.



Brent Williams-Ruth (pronouns: he/him)
Attorney-At-Law

Law Offices of Brent Williams-Ruth, a division of BWR Consulting, PLLC

Physical Address: 500 S 336th Street, Suite 214; Federal Way, WA 98003

**EFFECTIVE IMMEDIATELY** All mail sent through the USPS should be sent to the following address: PO BOX 3319; Federal Way, WA 98063

Office/Scheduling Phone: (253) 285-7751

Direct: (253) 285-7453

e-mail<mailto:Brent at Williams-RuthLaw.com> / website<http://www.williams-ruthlaw.com/> / facebook<http://www.facebook.com/bwrlaw> /
-------------- next part --------------
An HTML attachment was scrubbed...
URL: <http://mailman.fsr.com/pipermail/wsbarp/attachments/20240117/1b38497f/attachment.html>