FinCEN’s Frequently Asked Questions Regarding Customer Due Diligence Requirements for Financial Institutions
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On July 19, 2016, the Financial Crimes Enforcement Network (“FinCEN”) issued twenty-six Frequently Asked Questions (the “FAQs”) pertaining to the agency’s Customer Due Diligence rule (“CDD Rule”), published on May 11, 2016.  FinCEN issued the CDD Rule under the Bank Secrecy Act, clarifying and enhancing customer due diligence (“CDD”) requirements for financial institutions, and adding a new requirement for covered financial institutions to identify and verify the identity of the “beneficial owners” of certain of their legal entity customers.  FinCEN released the FAQs to assist covered financial institutions in understanding the scope of their CDD requirements.

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