The FinCEN Certification of Beneficial Ownership form is a one-page document your bank, brokerage, mutual fund, or futures dealer gives you when your business opens an account. You fill it out by listing every individual who owns 25 percent or more of the entity in Section I, naming one person who manages the business in Section II, and signing the certification at the bottom. The whole thing takes a few minutes once you have the right information in front of you.
What to Gather Before You Start
For every person you’ll list on the form, you need:
- Full legal name — first, middle initial, and last, exactly as it appears on government-issued ID.
- Date of birth.
- Residential or business street address. A P.O. box does not satisfy this field.
- Social Security number for U.S. persons.
- For non-U.S. persons: a Social Security number if they have one, or a passport number or similar government-issued identification number, along with the country of issuance.1Financial Crimes Enforcement Network. Certification of Beneficial Ownership Form
You also need the legal entity’s full name, entity type (corporation, LLC, partnership, and so on), and street address.
The form itself doesn’t require you to attach copies of photo identification. The bank verifies each beneficial owner’s identity separately using its own risk-based procedures, and it will usually ask for a driver’s license, passport, or other government-issued ID during that step.2eCFR. 31 CFR 1010.230 – Beneficial Ownership Requirements for Legal Entity Customers Have those documents ready.
Filling Out Section I: Ownership
Section I captures every individual who directly or indirectly owns 25 percent or more of the entity’s equity interests.3eCFR. 31 CFR 1010.230 – Beneficial Ownership Requirements for Legal Entity Customers Depending on how your business is structured, you might list anywhere from zero to four people here. The form has additional pages for a second, third, and fourth owner if you need them.1Financial Crimes Enforcement Network. Certification of Beneficial Ownership Form
An LLC with two 50/50 members lists both. A corporation with no single shareholder at 25 percent or higher can leave this section blank; follow the bank’s instructions on how to mark it as not applicable.
Indirect and Layered Ownership
Ownership doesn’t have to be direct. If a parent company holds 60 percent of your LLC and one individual owns 50 percent of that parent, that person indirectly owns 30 percent of your LLC and belongs in Section I. The rule looks through intermediate entities until it reaches a natural person.
When a trust holds 25 percent or more, the bank will generally want the person who controls the trust, usually the trustee. The form calls for natural persons, so the trust itself doesn’t go in the field.
Filling Out Section II: Control
Section II asks for exactly one individual with significant responsibility to manage or direct the entity. That’s typically a CEO, CFO, COO, president, managing member, or general partner. Section II always requires an entry, even when Section I is blank.3eCFR. 31 CFR 1010.230 – Beneficial Ownership Requirements for Legal Entity Customers
If the person you named in Section I as a 25-percent owner is also the one running the business, list them again in Section II. The fields are identical, so you’re entering the same name, date of birth, address, and identifying number twice. For a single-owner, single-manager business, one person fills both sections.
Signing and Handing It Back
The bottom of the form is a certification statement. The person opening the account signs and dates it, confirming that the information is complete and correct to the best of their knowledge. This signer doesn’t have to be a beneficial owner. It’s whoever is sitting across from the bank representative or logged into the digital portal, and their name also goes in the opening field of the form.1Financial Crimes Enforcement Network. Certification of Beneficial Ownership Form
Submission is straightforward. At a branch, you hand the completed form and any requested ID documents to the account representative. Many institutions also accept digital submission through their online portal, where you fill in the same fields and upload identification images. The account doesn’t activate until the bank verifies the beneficial owners’ identities, so legible documents at the outset move things along.
Whether Your Business Has to Fill It Out
Any business created by filing a document with a state office fills out the form when it opens an account at a covered financial institution. That covers corporations, LLCs, limited partnerships, and similar entities, as well as general partnerships and business trusts formed through state filings. It applies to entities registered to do business in the United States, not only those originally formed here.
A long list of entity types is exempt because they’re already heavily regulated or publicly transparent: publicly traded companies, banks and bank holding companies, SEC- and CFTC-registered entities, state-regulated insurers, Sarbanes-Oxley registered accounting firms, certain pooled investment vehicles, and a handful of others under 31 CFR 1010.230(e)(2). If any of these describe your entity, check the specific listing before assuming the form applies to you.
Nonprofit corporations get a partial exemption. Because they don’t have traditional equity owners, they skip Section I entirely. They still fill out Section II, naming one individual with control, typically a president, executive director, or board chair.4Federal Register. Customer Due Diligence Requirements for Financial Institutions
When You’ll Be Asked to Do It Again
Under a FinCEN order issued on February 13, 2026, banks are no longer required to collect a new certification every time an existing customer opens an additional account. The 2026 order (FIN-2026-R001) limits the collection requirement to three scenarios:
- The legal entity opens its first account with the institution.
- The bank becomes aware of facts that reasonably call into question the beneficial ownership information already on file.
- The bank’s ongoing due diligence procedures flag a need to refresh the information.5Financial Crimes Enforcement Network. FinCEN Exceptive Relief Order, FIN-2026-R001
In the second and third scenarios, the bank may just ask you to confirm in writing or verbally that the information on file is still accurate. A whole new form isn’t necessary unless something has actually changed. But if a beneficial owner has changed — someone sold their stake and dropped below 25 percent, a new investor crossed that threshold, or a different person took over management — the bank must collect, certify, and verify the new owner’s identity from scratch.6Financial Crimes Enforcement Network. CDD Rule FAQs
The obligation is on you to tell your bank when ownership changes. Loan renewals, CD rollovers, and similar product extensions no longer automatically trigger a new form, but the bank keeps discretion to ask for one based on its own risk assessment.
Penalties for Getting It Wrong
Willfully providing false information on the certification, or refusing to comply with the CDD requirements, is a federal crime under the Bank Secrecy Act. A willful violation carries a fine of up to $250,000, up to five years in prison, or both. If the violation is part of a pattern of illegal activity involving more than $100,000 in a twelve-month period, the ceiling rises to a $500,000 fine, ten years in prison, or both.7Office of the Law Revision Counsel. 31 USC 5322 – Criminal Penalties
These are criminal penalties that require a willful violation. An honest mistake or an outdated address doesn’t put anyone in prison. The conduct the statute targets is intentionally concealing an owner or listing a straw person to hide who really controls the business. On the bank’s side, the consequence for information it can’t verify is simpler: it declines the account, or closes one it already opened.
Not the Same as the BOI Report
The certification you give your bank is a separate obligation from the Beneficial Ownership Information (BOI) report filed directly with FinCEN under the Corporate Transparency Act. The bank certification stays with the bank for its own anti-money-laundering compliance and is never submitted to the government. The BOI report goes to FinCEN and is stored in a secure federal database.
As of March 26, 2025, FinCEN narrowed the BOI reporting requirement. Entities created in the United States are now exempt from filing BOI reports. Only entities formed under foreign law that have registered to do business in a U.S. state or tribal jurisdiction must file.8Financial Crimes Enforcement Network. Beneficial Ownership Information Reporting Filing one doesn’t satisfy the other. A foreign reporting entity that opens a U.S. bank account has to do both.
The information the two forms collect overlaps but isn’t identical. Both ask for the beneficial owner’s name, date of birth, and address. Only the bank certification asks for a Social Security number. The BOI report requires a copy of a specific identification document, while the bank certification does not, though the bank will usually ask for ID separately as part of its own verification.