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FINANCIAL & CAPITAL MARKETS

Beneficial ownership transparency

Beneficial ownership transparency in Financial & Capital Markets is no longer a compliance backlog item. The U.S. Financial Crimes Enforcement Network finalized its Corporate Transparency Act beneficial ownership reporting rule, with January 2024 deadlines now passed and enforcement attention shifting to financial institutions' customer due diligence obligations under 31 CFR Part 1010. The Financial Conduct Authority and European Banking Authority have each issued guidance tightening how firms must verify, record, and refresh beneficial ownership data across correspondent banking and fund distribution relationships.

Watch

  • FinCEN's CDD Rule amendment proposals expanding covered financial institution definitions
  • EBA revised AML/CFT guidelines: beneficial ownership verification timelines for fund managers
  • Corporate Transparency Act litigation: court injunctions affecting reporting deadlines remain active
  • APAC: MAS Notice SFA 04-N02 updates on beneficial ownership disclosure for capital markets licensees

Recent material activity in Financial & Capital Markets

Active monitoring in place across Financial & Capital Markets. Material developments related to beneficial ownership transparency will appear here as they are published.