Beneficial Ownership Certification


The Bank Secrecy Act requires that all financial institutions collect and verify the identities of certain individuals who own or control legal entities. The purpose of the provisions is to help the U.S. government’s fight against crimes to evade financial requirements that address terrorism and other national security threats.

The Beneficial Owner(s) Certification Form is provided below for your convenience and can be downloaded and printed. Completed forms require the signature of the individual providing the information. Please note this form may not be digitally signed.

The completed form should be provided to Bar Harbor Bank & Trust by the individual who will be opening the business account, in addition to all other business identity documents (see the FAQs).

This form must be completed before, or at, account opening.

The Beneficial Owner Form

When opening an account at Bar Harbor Bank & Trust, the Beneficial Owner(s) Certification Form must be completed by an individual authorized to open accounts or provide information on behalf of the legal entity, also known as a Natural Authorized Person. The form requires, among other information, the name, business address or primary residence address, date of birth, Social Security Number (as applicable), the name of the issuing state or country, and number of the passport or driver’s license for the Beneficial Owners and Control Person of the legal entity opening an account.

Download the Beneficial Owner(s) Certification Form


A beneficial owner is each individual with 25% or more equity interest in the legal entity, whether directly or indirectly (for certain clients, Bar Harbor Bank & Trust will advise if each individual with 10% or more equity interest is required).

A control person is a single individual with significant responsibility to control, manage, or direct a legal entity customer (e.g. executive officer or senior manager).

A natural authorized person (NAP) is an individual authorized to open accounts or provide information on behalf of the legal entity.

A legal entity is defined as:

  • Corporation
  • Limited liability company
  • Partnership
  • Other entity created by filing a public document with a Secretary of State or similar office
  • General partnership
  • Any similar entity formed under the laws of a foreign jurisdiction that opens an account

A legal entity does not include:

  • Sole proprietorships or unincorporated associations
  • Refer to the section on exclusions and exempt below for more details on whether your company is impacted by this requirement


The following legal entities are excluded from the Beneficial Ownership Rule and do not require the collection of Beneficial Ownership information or evidence supporting their exclusion:

  • Sole Proprietorships
  • Trusts (other than statutory trusts created by a filing with the Secretary of State or similar office)
  • Authorized Users for credit cards
  • Non-Account Owners


Legal entities in one of the following categories are generally exempt from the Beneficial Ownership Rules requirements. However, a completed form detailing exemption reasons and signed by the NAP will be required with the first account opened after the FinCEN regulatory date.

  1. Entities traded on a U.S stock exchange (NYSE, American or NASDAQ)
  2. A charity or non-profit entity (requires a Control Person)
  3. A Public Accounting firm registered under section 102 of the Sarbanes-Oxley Act
  4. A Bank regulated by a U.S. state agency
  5. An Insurance company regulated by a state of the United States
  6. A U.S regulated financial institution
  7. An agency of the U.S. Federal government
  8. An agency of a U.S. State government
  9. A U.S. local government agency
  10. A non-U.S. government agency engaged in government activities
  11. A bank holding company
  12. A savings and loan holding company
  13. Equipment Finance/Leasing transactions that are purchases from third parties as Bar Harbor Bank & Trust is not the originating bank
  14. A financial market utility designated by the Financial Stability Oversight Council
  15. A non-U.S. entity opening a private banking account subject to 31 CFR
  16. An issuer of a class of securities
  17. An SEC registered investment company, investment advisor, broker dealer or other registered firm with a current SEC registration number
  18. A Commodity Futures Trading Commission registered entity
  19. A pooled investment vehicle that is operated or advised by a financial institution that is exempt from Beneficial Ownership
  20. Non-excluded pooled investment vehicles—those not operated by or advised by a financial institution such as a non-US managed mutual fund, hedged fund or private equity fund (requires Control Person)
  21. An Entity, organized under the laws of the United States, with at least 51% of whose commons stock or analogous equity interest held by an entity traded on a U.S. Stock Exchange
  22. Unincorporated Associations (such as scout troops or youth sport leagues) (Unincorporated Associations are excluded and are not required to provide beneficial ownership and signature from a Natural Authorized Person)

Frequently Asked Questions

The Beneficial Ownership Certification form must be completed at the time a new business account is opened for a legal entity. The form includes identity information about the organization's beneficial owners that have a 25% ownership interest, identity information about one individual with managerial control, and a signature of the person providing and certifying this information.

Each time an account is opened for a Legal Entity, the Bank Secrecy Act will require us to ask you for specific identifying information: name, address, date of birth, social security number, as well as acceptable identification documentation, usually a driver’s license or passport, for those who meet the qualifications below:

  • EACH individual (natural person) who has 25% or more Beneficial Ownership in the Legal Entity; and
  • ONE individual who has Significant Managerial Control of the Legal Entity.

If you are opening a business account on behalf of a Legal Entity, you will be required to provide acceptable identification and to certify that this information is true and accurate to the best of your knowledge.

If no one owns 25% or more of the organization, you will still need to provide the information of one person who has significant managerial control of the organization. Examples, although not all inclusive, are a President, CEO, CFO, COO, Managing Member, or Controller.

If the organization is owned by an entity or entities, we are required to verify and identify each individual (natural person) of the entity that has a 25% or more ownership interest in the organization opening the account.

No. A beneficial owner can, but is not required to, be an authorized signer on the account.

If an owner does not have a social security number, they may provide a passport number or similar information.

Each time a business account is opened for a covered Legal Entity or certain maintenance is performed such as a title change or an authorized signer change, you will be asked to provide this additional information, even if this has been provided previously.

Bar Harbor Bank & Trust will only use this information to comply with the Bank Secrecy Act.

No. You are not required to complete a Beneficial Ownership Certificate for consumer accounts.