FinCEN CDD FAQ: Are covered financial institutions required to obtain information directly from the beneficial owners of legal entity customers?

Compliance > BSA > FinCEN CDD/BO Rule - eff 2016
Q:  Are covered financial institutions required to obtain information directly from the beneficial owners of legal entity customers?
 
A.  No.  The Rule requires financial institutions to obtain information about the beneficial owners of a legal entity from the individual seeking to open a new account at the covered financial institution on behalf of the legal entity customer.  This individual could, but would not necessarily, be a beneficial owner.
 
 
 
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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