FinCEN CDD FAQ: Are covered financial institutions required to include the procedures for identifying and verifying the identity of the beneficial owners of legal entity customers in the institution’s AML compliance program?

Compliance > BSA > FinCEN CDD/BO Rule - eff 2016
Q:  Are covered financial institutions required to include the procedures for identifying and verifying the identity of the beneficial owners of legal entity customers in the institution’s AML compliance program?
 
A.  Yes.  The CDD procedures must be included in the covered financial institution’s AML compliance program.
 
 
 
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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