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FinCEN's New Customer Due Diligence Rules: What You Need to Know

OnDemand Webinar (87 minutes)

Gain an understanding of the requirements and related developments with FinCEN's new customer due diligence rules.Banks and other financial institutions are required to identify and verify the identity of beneficial owners of legal entity customers under the Financial Crime Enforcement Networks' (FinCEN) new customer due diligence (CDD) rule. Many bank employees do not fully understand exactly when the CDD rule applies and what actions are required in order to satisfy their regulatory obligations. This topic helps the persons responsible for customer due diligence to understand which customers are covered by the CDD rule and which are excluded from the new requirements, as well as the specific information and documentation requirements for banks. It also guides banks in developing and implementing ongoing anti-money laundering policies to comply with FinCEN rules, including CDD requirements. This information is also critical for legal entity customers to understand their disclosure obligations when beginning new banking relationships, including in corporate transactions.


V. Gerard Comizio, Fried, Frank, Harris, Shriver & Jacobson LLP Michael T. Gershberg, Fried, Frank, Harris, Shriver & Jacobson LLP


Identifying Beneficial Owners

• Beneficial Owner Definitions and Thresholds

• Exclusions to Definition of Legal Entity Customer

• Complex Ownership and Control Structures

Verification and Documentation of Beneficial Owners

• Existing Customers vs. New Customers

• Product or Service Renewals

• Completing CTRs

Bank Policies and Procedures

• Risk-Based Determinations More Stringent Than CDD Rule

• Beneficial Ownership Certification Form

• Updating and Monitoring Customer Information

AML Program Requirements

• Nature and Purpose of Customer Relationship

• Ongoing Monitoring

• Updating Customer Information