FinCEN Geographic Targeting Orders

FinCEN Reporting Scenarios

WFG's internal interpretations of proper handling of various scenarios under the 4/13/18 Geographic Targeting Order.

Individual and Entity as Buyer

If I have 2 buyers in what would be a covered transaction and 1 is an individual and the other is not. . . .?

Until we have some official clarification, I’d take the conservative approach and report the transaction, but only show that there was a partial interest acquired by the entity.

--Alanfields (talk) 14:36, 20 May 2018 (PDT)

No Individual Owns 25% of Entity

In a reportable transaction, and there is no individual who owns 25% or more of the entity … ?

This scenario where no-one owns a 25% or more is definitely reportable. You would report the entity information, and the information about the person “primarily responsible” – but no detail about the beneficial owners (since as defined they are not beneficial owners under Section III.A). I would recommend making the notation that there are no 25% owners in the first field normally devoted to reporting beneficial owners.

This is summarized under "Purchases by a Legal Entity (Not through a Trust)" on page 3 of the GTO.

--Alanfields (talk) 14:36, 20 May 2018 (PDT)