FinCEN Issues FAQs on Customer Due Diligence

The Financial Crimes Enforcement Network today published three frequently asked questions regarding customer due diligence requirements. The questions address the risk-based procedures covered institutions are required to follow with regard to collecting and maintaining customer information, creating a customer risk profile and conducting ongoing monitoring of the relationship.

Among other things, the FAQs clarified that there is no fixed schedule for updating customer risk profiles. FinCEN also confirmed that additional analysis is not needed for customers who are assigned a low risk profile.