Regulators Explain Examination Approach for Compliance With FinCEN’s Customer Due Diligence Rule: FFIEC’s New Examination Procedures Align with FinCEN’s Rule and Existing Guidance; Impose No Lower Beneficial Ownership Threshold

Sullivan & Cromwell LLP - May 11, 2018

On May 11, 2018, the FFIEC issued much-anticipated guidance explaining the federal banking agencies’ examination approach for compliance with FinCEN’s CDD Rule, including its beneficial ownership requirement.