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ARTICLE · 13 APRIL 2018

Financial Regulatory Developments Focus – Apr 11, 2018 Issue 14/201

A&O Shearman
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On April 3, 2018, the U.S. Financial Crimes Enforcement Network released answers to 37 frequently asked questions regarding its final rule on Customer Due Diligence Requirements ...

United StatesFinance and Banking
A&O Shearman
A&O Shearman
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AML/CTF, Sanctions and Insider Trading

US Financial Crimes Enforcement Network Releases Customer Due Diligence FAQs

On April 3, 2018, the U.S. Financial Crimes Enforcement Network released answers to 37 frequently asked questions regarding its final rule on Customer Due Diligence Requirements for Financial Institutions, which was published in the Federal Register on May 11, 2016 and amended on September 29, 2017. This is the second series of FAQs FinCEN has released. The FAQs cover various topics in connection with the requirement that financial institutions obtain beneficial ownership information for legal entity customers, including the beneficial ownership threshold and its interaction with other AML program obligations, collection and verification of identifying information, particularly for legal entity customers with complex ownership structures and the definition of "legal entity customer," including the treatment of foreign financial institutions. The FAQs

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