This month marks the one-year anniversary of the Financial Crimes Enforcement Network (FinCEN)’s long-awaited beneficial ownership rule, which imposes certain Customer Identification Program (CIP) requirements under the Bank Secrecy Act (BSA). FinCEN proposed the rule in 2014 and finalized it in May 2016. FinCEN has also issued Frequently Asked Questions Regarding Customer Due Diligence Requirements for Financial Institutions, which provides guidance in understanding and implementing the new rule. All financial institutions subject to the rule must begin complying with it no later than May 11, 2018.
The rule will impose new compliance obligations on federally regulated banks, federally insured credit unions, mutual funds, brokers or dealers in securities, futures commission merchants, and introducing brokers in commodities. Continue Reading Key Steps in One-Year Countdown to Compliance with FinCEN’s Beneficial Ownership Rule