Compliance deadline for FinCEN CDD/Beneficial Ownership rules
FinCEN has submitted "Customer Due Diligence Requirements for Financial Institutions" final rules for Federal Register publication on May 11, 2016, to "clarify and strengthen customer due diligence requirements for: banks; brokers or dealers in securities; mutual funds; and futures commission merchants and introducing brokers in commodities. The rules contain explicit customer due diligence requirements and include the anticipated new requirement to identify and verify the identity of beneficial owners of legal entity customers, subject to certain exclusions and exemptions." Banks will have to use Customer Identification Program procedures to verify the identity of beneficial owners, although when documentation is used, banks can rely on copies. The rule allows banks to rely on information provided by the customer. The rules will be effective 60 days after publication (July 11, 2016); covered financial institutions must comply with the rules by May 11, 2018, two years after publication.
- PDF of rule (227 pages) as submitted for publication