FinCEN CDD FAQ: Who is a legal entity customer?

Compliance > BSA > FinCEN CDD/BO Rule - eff 2016
Q:  Who is a legal entity customer?
 
A.  The Rule defines a legal entity customer as a corporation, limited liability company, other entity created by the filing of a public document with a Secretary of State or similar office, a general partnership, and any similar entity formed under the laws of a foreign jurisdiction that opens an account.  The definition also includes limited partnerships, business trusts that are created by a filing with a state office, and any other entity created in this manner.
 
A legal entity customer does not include sole proprietorships, unincorporated associations, or natural persons opening accounts on their own behalf.
 
 
 
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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