On May 11, 2016, the Financial Crimes Enforcement Network (FinCEN), a bureau of the U.S. Department of Treasury, published its final rule addressing Customer Due Diligence Requirements for Financial Institutions (CDD Rule). Among other requirements, the CDD Rule will require banks, brokers or dealers in securities, mutual funds, and futures commission merchants and introducing brokers in commodities to collect information on the beneficial owners or “real persons” behind a legal entity when it opens a new account. The CDD Rule becomes effective on July 11, 2016, although compliance will be required by May 11, 2018.