News & Analysis as of

Beneficial Owner Customer Due Diligence (CDD) Customer Identification Program (CIP)

Constangy, Brooks, Smith & Prophete, LLP

Wire Fraud: Should banks CYA by tightening up on KYC?

After a long weekend, Finance Manager Joe sits at his desk to read his emails. One of the emails is from a trusted vendor with whom the Joe communicates on a regular basis, regarding an unpaid invoice that is due immediately....more

Ballard Spahr LLP

FinCEN Seeks to Make Investment Advisers Subject to Bank Secrecy Act

Ballard Spahr LLP on

Years in the making, on February 13, the Financial Crimes Enforcement Network (“FinCEN”) issued a notice of proposed rulemaking (“NPRM”) to include “investment adviser” (“IA”) within the definition of “financial institution”...more

Pillsbury - Global Trade & Sanctions Law

With CDD and Beneficial Ownership Rule in Effect, FinCEN Continues to Clarify and Refine Rules for Financial Institutions

Long awaited rules for “Customer Due Diligence Requirements for Financial Institutions” (the CDD Rules) went into effect on May 11, 2018. FinCEN has taken steps to clarify and refine implementation of the CDD Rules, issuing...more

Skadden, Arps, Slate, Meagher & Flom LLP

Tackling the Challenges of Complying With FinCEN’s New Customer Due Diligence Rule

Effective May 11, 2018, covered financial institutions are required to comply with the customer due diligence rule (the Rule) that the Financial Crimes Enforcement Network (FinCEN) finalized in May 2016. The Rule mandates the...more

Neal, Gerber & Eisenberg LLP

Treasury Proposes Regulations That Would Require Private Trust Companies to Establish or Enhance AML Programs and to Identify...

The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) published proposed regulations on August 25, 2016 that would require certain private trust companies utilized by high net worth individuals,...more

Troutman Pepper Locke

Final FinCEN Customer Due Diligence Rule Released – Concerns Abound as Covered Financial Institutions Grapple with Implementation

Troutman Pepper Locke on

The United States Department of Treasury’s Financial Crimes Enforcement Network’s (FinCEN) new customer due diligence rule released in May has caused concern throughout the industry. In what it says is an effort to prevent...more

WilmerHale

Anti–Money Laundering Alert: FinCEN Finalizes Beneficial Ownership and Customer Due Diligence Requirements

WilmerHale on

The Financial Crimes Enforcement Network (FinCEN) on May 11 released its long-awaited Final Rule (CDD Rule) that will require certain financial institutions to “look through” the nominal account holder to identify the...more

Eversheds Sutherland (US) LLP

FinCEN Customer Due Diligence Final Rules

On May 5, 2016, the U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) issued final rules (the Final Rules) on customer due diligence requirements for banks, securities broker-dealers, mutual funds, and...more

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