Anti–Money Laundering Alert: FinCEN Finalizes Beneficial Ownership and Customer Due Diligence Requirements

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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.

Please see full Alert below for more information.

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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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