On February 13, 2026, FinCEN issued an order granting exceptive relief to covered financial institutions from certain requirements under FinCEN’s Customer Due Diligence Requirements for Financial Institutions rule. The order exempts covered financial institutions from the requirement to identify and verify the beneficial owners of a legal entity customer each time the customer opens a new account.
Under the order, a covered financial institution is required to identify and verify the beneficial owners of a legal entity customer in only the following circumstances:
When a legal entity customer first opens an account with the institution;
When the institution has knowledge of facts that reasonably call into question the reliability of previously obtained beneficial ownership information; and
As otherwise required based on the institution’s risk-based procedures for ongoing customer due diligence.
Even with this exception, financial institutions must follow all other anti-money laundering and counter-terrorism financing rules under the BSA. This includes the requirement to continuously monitor transactions for any suspicious activity. Institutions must also keep customer information current and updated based on risk.
Read FinCEN‘s press release here.
The Order can be found here.
