FinCEN’s Customer Due Diligence Final Rule

Highlights of the long-awaited requirements

BETTY SANTANGELO AND MELISSA G.R. GOLDSTEIN, SCHULTE ROTH & ZABEL LLP

On May 11, 2016, the US Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) published its long-awaited Final Rule regarding the customer due diligence (“CDD”) requirements under the Bank Secrecy Act for banks, broker-dealers, mutual funds, and futures commission merchants and introducing brokers in commodities (collectively, “covered financial institutions”).1 The Final Rule requires these covered financial...

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