December 2018 JD Supra

On May 2016, FinCEN issued a “Fifth Pillar” of Customer Due Diligence (CDD) calling it the “CDD Rule”, which currently takes effect on May 11, 2018.   The CDD Rule applies to Covered Financial Institutions (federally regulated banks, federally insured credit unions, mutual funds, brokers or dealers in securities, futures commission merchants, and introducing brokers in commodities).  Covered Financial Institutions are responsible for detecting, monitoring, and reporting suspicious money laundering and illicit activities and “share the information” with law enforcement agencies