FinCEN has issued an order granting relief from part of its Customer Due Diligence rule, so banks no longer must re‑identify and re‑verify beneficial owners every time your company opens a new account or product. Instead, they focus ownership checks on initial account opening, when something about your information looks off, and when their risk‑based procedures say they should dig deeper.

The Core Change in Simple Terms

Under this exceptive relief, your bank must confirm your company’s beneficial owners only:

• At the first account opening with that institution.
• When they learn facts that call your existing ownership information into question.
• As needed under their ongoing risk‑based due‑diligence procedures.

They are no longer required to repeat the beneficial ownership process for each subsequent checking account, loan, or credit card you open with them.

Concrete Steps for Owners and IT

Owner/management actions:

• Keep ownership data clean: Maintain a current list of all beneficial owners (and key controllers) with legal names, tax data, and ownership percentages so you can certify accuracy quickly when requested.
• Align with your bank: Ask your relationship manager how they will apply the relief, what they will still ask for, and how your internal records can make their reviews faster.
• Tie into CTA/BOI: If your company is subject to beneficial ownership reporting, ensure your BOI filings, internal records, and the bank’s records are consistent.​

IT department actions:

• Centralize and secure records: Store ownership documents, formation records, and signatory forms in a secure repository with encryption, permissions, and audit logging.
• Implement change‑management: Put in a formal process so every ownership change, equity issuance, or leadership change creates an IT and compliance ticket to update records and access rights.
• Protect financial access: Enforce MFA, least‑privilege access, and monitoring on all systems connected to banking, payments, and accounting, supporting the bank’s risk‑based oversight with strong internal controls.​

Common Customer Questions (and Answers You Can Use)

• “Is my business still being monitored for suspicious activity?”
  Yes. The relief removes duplicated paperwork but does not change the Bank Secrecy Act’s risk‑based monitoring and reporting framework.
• “Will my bank ask for less paperwork now?”
  In many cases, yes, especially when opening additional accounts or services with the same institution, because they can rely on previously collected ownership information when appropriate.
• “Do I still need to tell my bank when ownership changes?”
  Absolutely. If the bank discovers that ownership data is outdated or inaccurate, they must revisit their due diligence, and delays or risk re‑assessment may follow.

How Farmhouse Networking Helps SMBs Turn Relief into Advantage

Farmhouse Networking helps small and midsize businesses convert regulatory changes into operational improvements by:

• Designing secure, centralized systems for ownership, governance, and banking documentation.
• Automating workflows triggered by ownership and leadership changes to keep systems, access, and records aligned.
• Strengthening IT security around financial systems so your risk profile stays low while your bank leans more on a risk‑based approach.

To learn how to implement these steps efficiently and securely, email support@farmhousenetworking.com for more information about how Farmhouse Networking can help improve your business.