Part of the Master FinCEN Reporting HUB.
You’ve determined the transaction is reportable. Now comes the question that makes rooms go quiet:
“Okay… so who’s filing it?”
Here’s the first thing you need to understand:
There is only one reporting person per reportable transfer.
Not two.
Not everyone involved.
Not “whoever feels like it.”
One.
FinCEN determines who that person is in one of two ways:
1. The Reporting Cascade
2. A Properly Executed Designation Agreement
Let’s start with the default rule…
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