AML: Who is your customer? FinCEN wants you to know

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May 2016


FinCEN has published its final Customer Due Diligence Rule (CDD Rule). The final rule is intended to help financial institutions avoid illicit transactions by improving their view of their clients’ identities and business relationships.

The final rule requires that financial institutions verify the identity of the beneficial owner of legal entity customers and imposes baseline requirements for customer due diligence procedures. While larger banks have already been strengthening such procedures as a result of regulatory enforcement actions, smaller banks, broker-dealers and mutual funds will need to significantly enhance their programs.

This Financial crimes observer analyzes the final rule’s requirements and provides our advice on what financial institutions should be doing now.

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Dan Ryan

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