News & Analysis as of

Financial Institutions Regulatory Requirements Customer Due Diligence (CDD)

A&O Shearman

PEP talk revisited: revised UK guidance on treatment of PEPs

A&O Shearman on

The UK Financial Conduct Authority (FCA) has issued finalised guidance on the treatment of politically exposed persons (PEPs) for anti-money laundering purposes. There is no significant shift in the FCA’s expectations of...more

Hogan Lovells

DAM(L’d) if you do, DAM(L’d) if you don’t – What should regulated firms be thinking about now the PoCA consent threshold has been...

Hogan Lovells on

On 10 July 2025, the UK raised the threshold below which certain regulated firms can perform acts that would otherwise constitute a money laundering offence. The new threshold is £3,000. This is the second rise in the...more

Seyfarth Shaw LLP

FinCEN's October 2024 Beneficial Ownership Information FAQ Update

Seyfarth Shaw LLP on

On October 3, 2024, the Financial Crimes Enforcement Network (FinCEN) issued new guidance concerning the Corporate Transparency Act (CTA) by updating and expanding on the Beneficial Ownership Information (BOI) Reporting...more

Holland & Knight LLP

FinCEN Reference Guide Clarifies Beneficial Ownership Reporting Requirements

Holland & Knight LLP on

The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) on July 26, 2024, issued a notice containing a reference guide for customers of financial institutions (the Reference Guide). The Reference...more

Orrick, Herrington & Sutcliffe LLP

FinCEN and Banking Regulators Clarify Due Diligence Requirements for Politically Exposed Persons

The Financial Crimes Enforcement Network (FinCEN) and federal banking regulators recently issued a Joint Statement intended to clarify the due diligence obligations of banks under the Bank Secrecy Act (BSA) regarding...more

Foodman CPAs & Advisors

Financial Institutions Continue to have CDD Questions and FinCen Responds

On August 3, 2020, FinCEN issued responses to three frequently asked questions (FAQs) regarding Customer Due Diligence (CDD) requirements for covered financial institutions.  FinCEN’s responses were done in consultation with...more

Foodman CPAs & Advisors

Las Instituciones Financieras Continúan Teniendo Preguntas sobre el “CDD” y FinCEN responde

El 3 de agosto del 2020, FinCEN emitió respuestas a tres preguntas frecuentes (“FAQ”) para las Instituciones Financieras cubiertas sobre los requisitos de Diligencia Debida del Cliente (“CDD”). ...more

Sullivan & Worcester

FFIEC Examination Procedures for the Beneficial Ownership Rule

Sullivan & Worcester on

The FFIEC has updated its BSA/AML manual effective May 5, 2018, to add a section on the new legal entity due diligence requirements and to update the section of the manual on customer due diligence generally. The Fed...more

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