FinCEN issued interpretive guidance in connection with the customer due diligence (“CDD”) requirements of the CDD Rule. Pursuant to the CDD Rule, published on May 11, 2016, covered financial institutions must now obtain, verify, and record the identities of beneficial owners of legal entity customers. Further, covered financial institutions must now implement and maintain appropriate risk based procedures for conducting ongoing customer due diligence, to include, understanding the nature and purpose of the customer relationships, conducting ongoing monitoring to identify and report suspicious transactions and, on a risk basis, to maintain and update customer information.
Covered financial institutions will have until May 11, 2018, two years from the date the final CDD Rule was published in the Federal Register, to implement and comply with the CDD Rule.
