FinCEN Issues Frequently Asked Questions Regarding Customer Due Diligence Requirements: Frequently Asked Questions Clarify Aspects of Beneficial Ownership Threshold, Identity Collection and Verification, and Ongoing Customer Due Diligence Obligations

Sullivan & Cromwell LLP - April 30, 2018
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The customer due diligence rules, which will become applicable on May 11, 2018, require covered financial institutions to collect and verify the identity of beneficial owners of legal entity customers. This memorandum discusses frequently asked questions issued by the Financial Crimes Enforcement Network on April 3, 2018 providing guidance on aspects of the customer due diligence rules, including beneficial ownership thresholds, identity collection and verification, and ongoing customer due diligence obligations.