Beneficial Ownership Structuring Scheme – What could be hidden just below that 25% line? In May 2016 FinCEN released their Final Rule on Beneficial Ownership and Risk-Based Customer Due Diligence. Beneficial Ownership is the “fifth pillar” for anti-money laundering (AML) programs under FinCEN’s rules for banks. Money launderers use transaction structuring to evade triggering of...