No. If the name on the identification document of a beneficial owner or company applicant does not match their current full legal name due to a recent legal name change, the individual’s current full legal name should be reported to FinCEN. The individual may report an acceptable identifying document that does not include the updated full legal name. This also applies when an individual is requesting a
FinCEN identifier.
If the requester obtains a new driver’s license or other acceptable identifying document that includes a changed name, address, or identifying number, the requester should update the information already provided to FinCEN, either by filing an updated beneficial ownership information report or updating the previously filed FinCEN identifier information, including by submitting an image of the new identification document.
Related Articles: What events require me to file an updated beneficial ownership information report?
What events require me to file an updated beneficial ownership information report?