FinCEN CDD FAQ: Are covered financial institutions required to use the Certification Form that is in Appendix A of the final CDD Rule?

Compliance > BSA > FinCEN CDD/BO Rule - eff 2016
Q:  Are covered financial institutions required to use the Certification Form that is in Appendix A of the final CDD Rule?
 
A.  No.  The Certification Form is provided as an optional form that financial institutions may use to obtain the required beneficial ownership information.  Financial institutions may choose to comply by using the sample Certification Form, using the institution’s own forms, or any other means that complies with the substantive requirements of this obligation.
 
 
 
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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