What Information Must Be Included In the FinCEN Report?
This is important to have available in advance of completing the FinCEN online report. The following is from FinCEN Q&A #12 &13.
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Company Information
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Its legal name
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Any trade names, “doing business as” (dba), or “trading as” (ta) names
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The current street address of its principal place of business if that address is in the United States (for example, a domestic reporting company’s headquarters), or, for reporting companies whose principal place of business is outside the United States, the current address from which the company conducts business in the United States (for example, a foreign reporting company’s U.S. headquarters).
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Its jurisdiction of formation or registration; and
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Its Taxpayer Identification Number.
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A reporting company will also have to indicate the type of filing it is making (that is, whether it is filing an initial report, a correction of a prior report, or an update to a prior report).
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Each individual beneficial owner or company applicant:
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The individual’s name, date of birth, and address
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A unique identifying number from an acceptable identification document; and
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The name of the state or jurisdiction that issued the identification document
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Address: For a beneficial owner, the reporting company must report the residential street address.
For a company applicant, the reporting company must report the individual’s residential street address. However, if an individual engages in the business of corporate formation (e.g., as an attorney or corporate formation agent) and files the formation or registration document during that business, then the reporting company must report the current street address of the company applicant’s business. For example, if the company applicant is a paralegal who filed the document while working at a law firm, the reporting company must report the business address of the law firm where the paralegal worked when filing the document.
Identification Documents
The list below sets out the forms of acceptable identification documents:
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A non-expired driver’s license issued by a U.S. state. A “U.S. state” means any state of the United States, the District of Columbia, the Commonwealth of Puerto Rico, the Commonwealth of the Northern Mariana Islands, American Samoa, Guam, the U.S. Virgin Islands, and any other commonwealth, territory, or possession of the United States.
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A non-expired identification document issued by a U.S. state or local government, or Indian Tribe that is issued for the purpose of identifying the individual. For example, a non-driver identification card issued by a state Department of Motor Vehicles would qualify because it is issued for identification purposes.
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A non-expired passport issued by the U.S. government; or
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If the individual does not have any of the three forms of identification document described above, the reporting company may provide the identifying number from a non-expired passport issued by a foreign government.
In addition, the reporting company must submit an image of the identification document associated with the unique identifying number reported to FinCEN.