FinCEN’s retreat from domestic beneficial-ownership reporting does not remove banks’ obligation to understand who controls their customers; it shifts more of that burden from a centralized government database into private compliance infrastructure. The real issue is not document collection but entity resolution. Banks increasingly need to connect owners, companies, addresses, counterparties and transaction histories into usable corporate identity graphs that can surface hidden relationships and changing risk. The policy change could widen the compliance-capability gap between institutions. Large banks can build or buy sophisticated ownership intelligence, while smaller institutions may face rising dependence on third-party data providers just to reconstruct information the federal system was originally designed to standardize.