The Financial Crimes Enforcement Network today published a long-expected set of frequently asked questions on expanded customer due diligence requirements under the Bank Secrecy Act, including a new requirement for banks to identify and verify legal entities’ “beneficial owners” when accounts are opened. The customer due diligence rule’s mandatory compliance date is May 11.
Supplementing a set of FAQs issued in 2016, the 37 new FAQs respond to many questions that have been raised by the industry since the rule was adopted. Now that the FinCEN FAQs have been issued, the federal banking agencies are expected to release their examination procedures in the coming days.
The American Bankers Association is reviewing the FAQs and will publish a staff summary as soon as possible. Meanwhile, ABA has been developing its own FAQs for bankers. Once coordinated with the FinCEN guidance, ABA will publish more FAQs as an additional resource for ABA members. For more information, contact ABA’s Rob Rowe.