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FinCEN Issues Highly Anticipated CDD Beneficial Ownership FAQs

On April 3, 2018, FinCEN issued a frequently asked questions (FAQ) document, FIN‐2018‐G001, discussing the Beneficial Ownership Rules which go into effect on May 11, 2018.

  • The FAQ addresses the following topics, among others:
  • Beneficial Ownership Threshold
  • Interaction of the beneficial ownership threshold with other AML program obligations
  • Collection of beneficial ownership information for direct and indirect owners: Legal entity customers with complex ownership structures
  • Identification and Verification methods
  • Collection of beneficial ownership information
  • Retention of beneficial ownership information
  • Obligation to solicit or update beneficial ownership information absent specific risk‐based concerns
  • Monitoring and updating information
  • Definition of legal entity, charities, non‐profits, etc.
  • Private Label Retail Credit
  • Equipment Finance and Lease Exemption
  • Treatment for CTRs
  • Impact of the rule on AML process
  • Customer relationship/Customer risk

One of the big questions out there is whether business account loan renewals or certificate of deposit rollovers require a certification at the time of renewal. Check out Question 12 for the important details!

These FAQs are a supplemental document to the first set of FAQs issued as FIN‐2016‐G003 back on July 19, 2016.

Join us on Tuesday, April 10, 2018 for a special Tuesdays with TCA webinar discussing the newly‐published FAQs for Customer Due Diligence/Beneficial Ownership. Contact us at [email protected] or (800) 934‐7347.

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