News & Analysis as of

Customer Identification Program (CIP) Financial Institutions Beneficial Owner

Skadden, Arps, Slate, Meagher & Flom LLP

FinCEN Seeks To Expand Reach of the BSA and Modernize Customer Identification Regulations

The U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) has recently taken steps to expand the reach of the Bank Secrecy Act (BSA) and related customer identification regulations. These steps build on...more

Pillsbury Winthrop Shaw Pittman LLP

FinCEN’s Proposed Rule to Regulate Investment Advisers: The Questions Industry Should Be Following

FinCEN is focused on customer due diligence, and both the 2024 Investment Adviser Risk Assessment and proposed rule indicate that investment advisers will be expected to assess customer identity, business model, and sources...more

Pillsbury - Global Trade & Sanctions Law

With CDD and Beneficial Ownership Rule in Effect, FinCEN Continues to Clarify and Refine Rules for Financial Institutions

Long awaited rules for “Customer Due Diligence Requirements for Financial Institutions” (the CDD Rules) went into effect on May 11, 2018. FinCEN has taken steps to clarify and refine implementation of the CDD Rules, issuing...more

Skadden, Arps, Slate, Meagher & Flom LLP

Tackling the Challenges of Complying With FinCEN’s New Customer Due Diligence Rule

Effective May 11, 2018, covered financial institutions are required to comply with the customer due diligence rule (the Rule) that the Financial Crimes Enforcement Network (FinCEN) finalized in May 2016. The Rule mandates the...more

Neal, Gerber & Eisenberg LLP

Treasury Proposes Regulations That Would Require Private Trust Companies to Establish or Enhance AML Programs and to Identify...

The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) published proposed regulations on August 25, 2016 that would require certain private trust companies utilized by high net worth individuals,...more

Locke Lord LLP

Final FinCEN Customer Due Diligence Rule Released – Concerns Abound as Covered Financial Institutions Grapple with Implementation

Locke Lord LLP on

The United States Department of Treasury’s Financial Crimes Enforcement Network’s (FinCEN) new customer due diligence rule released in May has caused concern throughout the industry. In what it says is an effort to prevent...more

Goodwin

FinCEN Issues Final Customer Due Diligence Rule

Goodwin on

The U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) has expanded the due diligence obligations of certain financial institutions that are subject to a customer identification program requirement under...more

Stinson LLP

New FinCEN Rule Requires Heightened Identification Procedures and Anti-Money Laundering Diligence

Stinson LLP on

A new Financial Crimes Enforcement Network (FinCEN) rule under the Bank Secrecy Act will require institutions to more specifically identify legal entity customers and increase anti-money laundering diligence. The rule will...more

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