A Step-by-Step Guide on Submitting a Beneficial Ownership Information Report

Transparency and accountability are crucial elements in modern business practices. For this reason, governments across the globe have implemented regulations requiring companies to disclose their beneficial ownership information. This information aims to identify the individuals who ultimately own or control a business entity, aiding in the fight against money laundering, corruption, and other illicit activities. Submitting a Beneficial Ownership Information Report is essential for compliance, and here’s a comprehensive guide on how to navigate this process.

1. Understand the Regulations: Familiarize yourself with the specific regulations and deadlines set forth by the governing body in your jurisdiction. These requirements may vary from country to country or state to state, so it's crucial to be well-versed in the local laws.

2. Identify Beneficial Owners: Determine who qualifies as a beneficial owner according to the regulations. Typically, this includes individuals who own or control a significant percentage of the company or have significant influence over its operations.

3. Gather Required Information: Collect detailed information about each beneficial owner, such as their full name, date of birth, residential address, nationality, and the nature of their ownership or control.

4. Compile Documentation: Gather supporting documents that validate the provided information, such as identification documents (passport, driver’s license), proof of address, shareholding certificates, or any agreements outlining ownership.

5. Utilize Beneficial Ownership Platforms: Many jurisdictions provide online platforms or filing systems specifically designed for submitting beneficial ownership information. Utilize these platforms, if available, to streamline the submission process.

6. Complete the Report Form: Fill out the necessary forms accurately and thoroughly. Double-check all the information provided to ensure accuracy and compliance with the regulatory requirements.

7. Review and Verification: Review the completed report for any errors or inconsistencies. Verify that all necessary documentation has been attached and that the information provided aligns with the regulations.

8. Submit within the Deadline: Ensure timely submission of the report between Jan 1, 2024 and January 1, 2025. Missing deadlines can result in penalties or non-compliance issues, so adhere strictly to the specified timeline.

9. Maintain Updated Records: Regularly update the beneficial ownership information in accordance with any changes that occur within the company’s structure or ownership.

10. Seek Professional Assistance if Needed: If you encounter complexities or uncertainties during the process, seek guidance from legal or financial professionals well-versed in beneficial ownership regulations. Their expertise can help navigate intricate situations.

11. Stay Informed: Stay abreast of any updates or amendments to the regulations pertaining to beneficial ownership reporting to ensure ongoing compliance.

 Frequently Asked Questions

What is a BOI?

Beneficial ownership information refers to identifying information about the individuals who directly or indirectly own or control a company.

What is a FinCEN identifier?

A “FinCEN identifier” is a unique identifying number that FinCEN will issue to an individual or reporting company upon request after the individual or reporting company provides certain information to FinCEN. An individual or reporting company may only receive one FinCEN identifier. Individuals may request a FinCEN identifier starting January 1, 2024, by completing an electronic web form at https://fincenid.fincen.gov. Individuals will need to provide their full legal name, date of birth, address, unique identifying number and issuing jurisdiction from an acceptable identification document, and an image of the identification document. After an individual submits this information, they will immediately receive a unique FinCEN identifier. An individual or reporting company is not required to obtain a FinCEN identifier.

What businesses need to submit the BOIR?

All businesses must submit a BOIR, with the exception of

• Securities reporting issuer;
• Governmental authority;
• Bank;
• Credit union;
• Depository institution holding company;
• Broker or dealer in securities;
• Securities exchange or clearing agency;
• Other Exchange Act registered entity;
• Investment company or investment adviser;
• Venture capital fund adviser;
• Insurance company;
• State-licensed insurance producer;
• Commodity Exchange Act registered entity;
• Accounting firm;
• Public utility;
• Financial market utility;
• Tax-exempt entity; or
• Large operating company.

Go to https://www.fincen.gov/boi

Click on File

Click on File BOIR

The application is broken down into 5 components (Filling information, reporting company, company applicants, beneficial owner, and submit)

Filing information

1. Type of filing
   1. Initial report
   2. Correct prior report
   3. Update prior report
   4. Newly exempt entity
2. Date prepared

Reporting Company

3. Request to receive FinCEN ID
4. Foreign pooled investment vehicle
5. Reporting company legal name
6. Alternate name
7. Tax Identification type
   1. EIN
   2. SSN
   3. Foreign
8. Tax identification number ( 9 digitis, leave out dashes)
9. Country (if foreign tax ID only)
10. Country
    1. Country: USA
    2. State of formation: Connecticut
    3. Tribal jurisdiction of formation: NA
    4. Name of other tribe: NA
11. Address (Number, street, apt)
12. City
13. US or US Territory
14. State
15. Zip code
16. Existing reporting (check if reporting company as of Jan 1, 2024

Company Applicant

17. (question for future not yet available)
18. Company applicant FinCEN ID
19. Last name
20. First name
21. Middle name
22. Suffix
23. Date of birth (MM/DD/YYYY)
24. Address type
25. Address
26. City
27. Country
28. State
29. Zip code
30. Identifying type
    1. State issued Drivers license
    2. State/local/Tribal issued ID
    3. US Passport
    4. Foreign passport
31. Identifying document number
32. Identifying document issuing jurisdiction
    1. Country
    2. Stage
    3. Local
    4. Other local/tribal
33. Identifying document image
34. Item reserved for future use
35. Parent/Guardian instead of minor child
36. FinCEN ID

Beneficial Owners

37. Exempt entity
38. Last name
39. First name
40. Middle name
41. Suffix
42. Date of birth (MM/DD/YYYY)
43. Address
44. City
45. Country
46. State
47. Zip code
48. Identifying type
49. Identifying document number
50. Country
51. State
52. Local/tribal
53. Other local/tribal description

Submit

54. Email
55. Confirm email
56. First name
57. Last name

Check box *I certify that I am authorized to file this BOIR on behalf of the reporting company. I further certify, on behalf of the reporting company, that the information contained in this BOIR is true, correct, and complete.

Check box I am human

Complete captcha

Read disclaimer

The willful failure to report complete beneficial ownership information to FinCEN, the willful failure to update beneficial ownership information provided to FinCEN when previously reported information changes, or the willful provision of false or fraudulent beneficial ownership information to FinCEN, may result in civil or criminal penalties. A person may also be subject to civil or criminal penalties for willfully causing a reporting company to report incomplete or false beneficial ownership information to FinCEN.

Submit form

Save transcript in records as proof of completion.  

Submitting a Beneficial Ownership Information Report is not only a legal obligation but also a crucial step in promoting transparency and combating financial crimes. By following these steps diligently and ensuring accurate and timely submissions, businesses contribute to a more accountable and ethical global business environment.