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 account's beneficial owners who own or control (directly or indirectly) certain legal entity customers. The rule also establishes a “fifth pillar” in FinCEN's AML Program requirement that mandates that certain institutions implement risk-based procedures for conducting customer due diligence.