OMB Reviewing Significant AML Proposed Rule

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On April 11, the Treasury Department submitted to the OMB’s Office of Information and Regulatory Affairs (OIRA) FinCEN’s long-awaited proposed rule to establish customer due diligence requirements for financial institutions. Under executive order, each agency is required to submit for regulatory review rules resulting from “significant regulatory actions,” and OIRA has 90 days to complete or waive the review. The public portion of the FinCEN rulemaking has been ongoing since February 2012 when FinCEN released an advance notice of proposed rulemaking to solicit comment on potential requirements for financial institutions to (i) conduct initial due diligence and verify customer identities at the time of account opening; (ii) understand the purpose and intended nature of the account; (iii) identify and verify all customers’ beneficial owners; and (iv) monitor the customer relationship and conduct additional due diligence as needed. FinCEN subsequently held a series of roundtable meetings, summaries of which it later published.

Topics:  Due Diligence, FinCEN, OIRA, OMB, Proposed Regulation

Published In: Finance & Banking Updates

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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