- Exemption applies to an entity "whose ownership interests are controlled or wholly owned, directly or indirectly, by one or more entities …" of the types that are exempt from reporting, other than a money transmitting or money services business, a pooled investment vehicle, an entity assisting a tax-exempt entity or an inactive entity
- Jan, 2024 - FinCEN provided a much-needed clarification of the exemption titled "Subsidiary of Certain Exempt Entities“
- Under its clarification, FinCEN provided that a subsidiary whose ownership interests are partially controlled by an exempt entity does not qualify for the Subsidiary Exemption. The FAQ states as follows: If an exempt entity controls some but not all of the ownership interests of the subsidiary, the subsidiary does not qualify. To qualify, a subsidiary's ownership interests must be fully, 100 percent owned or controlled by an exempt entity.