FinCEN Final Rule CDD

Fenergo’s centralized, rules-driven regulatory platform is purpose-built to help your financial organization comply with FinCEN CDD final rule obligations.

Coming into force on May 11th, 2018, FinCEN’s Final Customer Due Diligence (CDD) Rule will require financial institutions to enforce risk-based procedures for conducting ongoing Customer Due Diligence and Know Your Customer (KYC) processes. Known as the Fifth Pillar of AML/BSA compliance, this regulation promises to improve global corporate transparency by requiring financial institutions to identify and verify the identity of the beneficial owners of legal entity customers that open new accounts.

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BLOGS

  • FinCEN Final Rule: Redefining Client Due Diligence Requirements

    FinCEN’s Final Customer Due Diligence (CDD) Rule (i.e. FinCEN Final Rule (CDD)) will bring in sweeping new changes to how financial institutions collect, maintain and act upon beneficial ownership information and conduct customer due diligence.

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  • FinCEN Final Rule: 4 Data Management Considerations

    Based on our analysis of the Rule, there are four key examples of ambiguity around the regulatory expectations for CDD and beneficial ownership data management that covered financial institutions (FIs) should be aware of.

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  • UBO in Focus: FinCEN Final Rule vs 4th EU Money Laundering Directive

    This blog explores the ultimate beneficial ownership requirements under FinCEN’s Final Rule and the 4th EU Money Laundering Directive and the challenge posed by different percentages of ownership across different regulations.

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RESOURCES

whitepaper

FinCEN Final Rule Best Practice

In this paper we cover how the FinCEN Final Rule affects beneficial ownership disclosure requirements, the 10 major implementation challenges banks can expect to encounter in the coming months and 8 best practice approaches to enable you to deliver an efficient, risk-based approach to meet the full remit of FinCEN’s final rule.

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blog

13 Points of Clarification for FinCEN Final Rule (CDD)

FinCEN has released their eagerly awaited frequently asked questions (FAQ) document, providing additional guidance under 37 questions pertaining to the rule.

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FinCEN Final Rule - A Long Time in the Making

  • 2010

    FinCEN, SEC and CFTC issue joint guidance to clarify expectations for obtaining beneficial ownership information

  • 2012

    FinCEN issue an ANPR to help establish a common and more prescriptive definition of a beneficial owner

  • 2013 - 2014

    U.S. presents Action Plan for Beneficial Ownership to G-8

    FinCEN issue NPR permitting FIs to exercise their own risk-based judgement

  • 2018

    FinCEN Final Rule comes into force on May 11th

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