April 2018 JD Supra

Covered Financial Institutions (CFI) have until May 11, 2018 to implement and comply with the Financial Crimes Enforcement Network (FinCEN) Final Customer Due Diligence Rule (the CDD Rule).   The CDD Rule imposes a new requirement for CFIs to identify and verify the identity of beneficial owners of legal entity customers.  Meaning, legal entity customers must identify to the CFIs their ultimate Beneficial Owner (BO) or owners and not “nominees” or “straw men.”