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The Financial Crimes Enforcement Network (FinCEN) on April 3, 2018 published guidance on the Customer Due Diligence Requirements for Financial Institutions rule (the “CDD Rule) that will come into effect on May 11, 2018. FinCEN’s CDD Guidance, in the form of frequently asked questions, is comprised of 36 questions and answers covering a range of issues, from the scope of due diligence up the ownership chain of legal entities to due diligence requirements applicable (or not) to foreign banks.

The FinCEN CDD Guidance is available here, and contains links to the final CDD rule published on May 11, 2016, as amended on September 29, 2017.

For an excellent discussion of FinCEN’s CDD Guidance, see Brian Monroe, FinCEN FAQ brings clarity on new beneficial ownership rules, but some ambiguity remains, Association of Certified Financial Crime Specialists (April 13, 2018).


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