FinCEN CDD FAQ: Does a covered financial institution have to obtain beneficial information on existing accounts?

Compliance > BSA > FinCEN CDD/BO Rule - eff 2016
Q:  Does a covered financial institution have to obtain beneficial information on existing accounts?
 
A.  No.  The rule does not cover existing accounts that were opened before the applicability date.
 
 
 
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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