FinCEN 2017 Amendment: Besides Amending Their Certification Form, What Other Corrections Were Made?

Compliance > BSA > FinCEN CDD/BO Rule - eff 2016
Q:  Besides Amending Their Certification Form, What Other Corrections Were Made?
 
A:   In this rule, FinCEN also added a paragraph to 31 CFR 1024.210(b) which was inadvertently omitted from the earlier final rule. 
 
The document also makes a technical correction in 31 CFR 1024.210 by reinserting the training element of the AML program requirements for mutual funds, which was inadvertently omitted from the final rule. Consistent with 31 U.S.C. 5318(h)(1)(C) and the AML program requirements for mutual funds adopted in 2002,2 the training element appeared in the proposal amending the AML program requirements for mutual funds to add a new requirement relating to customer due diligence.3 In the final rule, however, the training element was inadvertently omitted from 31 CFR 1024.210(b). The training element is being reinserted by this correction document.
 
 
ADDITIONAL INFORMATION:
FinCEN’s Correction for Customer Due Diligence Requirements for Financial Institutions may be found here:   https://www.gpo.gov/fdsys/pkg/FR-2017-09-28/pdf/2017-20777.pdf
 

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