FinCEN Issues Exceptive Relief Order On Beneficial Ownership Verification Requirements

1 FinCEN Issues Exceptive Relief Order on Beneficial Ownership Verification Requirements

On February 13, the US Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) issued an order granting exceptive relief to covered financial institutions from certain requirements under the 2016 Customer Due Diligence Requirements for Financial Institutions rule (2016 CDD Rule). The relief eliminates the requirement to identify and verify beneficial owners of legal entity customers at each new account opening. Instead, covered financial institutions must identify and verify beneficial ownership only (1) when a legal entity customer first opens an account with the institution, (2) when the institution has knowledge of facts that reasonably call into question the reliability of previously obtained beneficial ownership information, or (3) as needed based on the institution's risk-based procedures for ongoing customer due diligence. All other anti-money