FinCEN CDD FAQ: Must a covered financial institution’s procedures for identifying and verifying the identity of beneficial owners of legal entity customers be identical to its customer identification program?

Compliance > BSA > FinCEN CDD/BO Rule - eff 2016
Q:  Must a covered financial institution’s procedures for identifying and verifying the identity of beneficial owners of legal entity customers be identical to its customer identification program?
 
A.  No.  However, the CDD Rule requires that the procedures, at a minimum, contain the same elements as required for verifying the identity of customers that are individuals under the applicable CIP rule.  However, financial institutions may use photocopies or other reproductions of identification documents in the case of documentary verification.
 
 
 
This FAQ, and others, was released in July 2016.  The 2016 FAQs were issued to assist institutions in understanding the scope of the Customer Due Diligence (CDD) requirements that were published in May 2016.   They may be found here:  https://www.fincen.gov/statutes_regs/guidance/pdf/FAQs_for_CDD_Final_Rule_(7_15_16).pdf
 

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