Posts in Financial Institutions.
In AML/BSA rule amendments published May 11, FinCEN will require "covered financial institutions" to implement new beneficial-owner identification and verification as part of their Customer Due Diligence ("CDD") and adopt risk-based supervisory procedures for their AML/BSA programs.
The Amendments require use of a prescribed Beneficial Owner reporting form, or its substantial equivalent. Though effective July 11, covered institutions have until May 11, 2018 to comply. See 31 C.F.R. § 1010.230 & App. A. FinCEN's AML/BSA requirements impose the "four pillars" of AML ...
Posted in: Financial Institutions
Tags: AML, Beneficial-Owner Look-Through, BSA, burr forman, CCD, Consumer Finance Litigation, Consumer Finance Litigation & Arbitration, Consumer Finance Litigation blog, Customer Due Diligence, financial institutions, FinCEN