For each beneficial owner or company applicant a company is required to report, the company must provide an identifying number from an acceptable identification document as well as an image of the identification document used to obtain this identifying number. Does the name on an individual’s acceptable identification document need to match the individual’s current full legal name?

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. See Question F.5 “What are acceptable forms of identification that will meet the reporting requirement?” for a list of the acceptable forms of identification