Countering corruption: Beneficial ownership, Real-estate transactions

With new issuances from FinCEN and the Administration’s focus on anti-corruption, companies should expect both additional rulemakings and increased regulatory attention on matters involving beneficial ownership/CDD, SAR filings, and anti-corruption compliance programs. (Note: FinCEN’s proposal for reporting beneficial ownership information is the first of three rulemakings that will implement the provisions of the CTA and inform the content of a national database on corporate ownership. The additional rulemakings, which will work in concert with this rulemaking when final, will address creation of the beneficial ownership registry and related amendments to the CDD rules.)