FinCEN’s expanded access to the beneficial ownership database opened to more institutions this quarter, and in an internal vendor probe last week we tied a shell to a related party in 90 minutes. For those running internal investigations and compliance audits, are you revising escalation criteria now that BOI lookups can be captured in workpapers and supported in audit trails?
Feels like moving from flashlight to floodlight, but we still ‘trust but verify’ against SOS filings. We tightened escalation to auto-trigger when BOI shows 25%+ held via a nominee service or entities formed in our high‑risk jurisdictions, and we capture the FinCEN query ID and purpose in the workpapers instead of the full extract. Are you also retaining the access certification per 31 CFR 1010.955 so the audit trail passes examiner review?
We’re adding an auto-escalation when BOI shows the “control person” is a professional formation agent or there are 2+ layers between UBO and opco, and we log the FinCEN request ID/timestamp in workpapers with a 30‑day re-check before finalizing — like speed dial that still needs a quick sanity call. @clinton_b57, are you redacting DOB/ID fields in exports or keeping them intact for subpoena readiness?
That “90 minutes” turnaround is exactly why we added a Tier 2 kick whenever the FinCEN record lists a mailbox/virtual office address or the company applicant is a filing service; we grab the request ID and PDF the response into workpapers for the trail — , the mailbox trend drives me nuts. @clinton_b57 are you scoping this globally or carving out exceptions for legacy vendors?