BSA/AML Beneficial Ownership Rules

• Overview

Gain a better understanding of FinCEN's CDD Rule that amends existing BSA regulations.It has been one year since covered entities have been required to comply with the requirements the Financial Crimes Enforcement Network's (FinCEN) customer due diligence rule (CDD Rule). As covered entities have implemented the CDD rule over the last year, questions have arisen in real time as to the CDD Rule's scope, application, and exclusions. This topic is intended to provide covered entities and their customers with an overview of the CDD Rule's requirements, best practices, and insight into what practitioners have seen when implementing the rule. In addition, it provides an overview of what regulators may potentially review when examining covered entities for compliance with the rule.

Authors

Agenda

Overview of Customer Due Diligence Rule

• Rule Requirements

• Implementation

• Practical Considerations

What We've Seen in the Year Since Mandatory Compliance

• Covered Entity Considerations

• Legal Entity Customer Considerations

What We Expect From Regulators

• Risk Profiles

• Reliance on Exceptions From Rule Requirements