Apr 18, 2023
The Financial Crimes Enforcement
Network (“FinCEN”) recently waded into unexpected controversy with
the release of proposed data fields for the beneficial ownership
information (“BOI”) reporting regime that will take effect at the
beginning of next year. FinCEN’s inclusion of “Unknown” and “Unable
to identify” options for several of the proposed data fields has
generated concern that incomplete BOI may be less valuable for some
users, such as financial institutions. These concerns stand in
contrast to the potential impossibilities and practical constraints
that reporters of BOI face. Please join Mayer Brown partners Brad
Resnikoff and Matt Bisanz as they discuss this controversy and how
it may affect the implementation of the BOI reporting regime.