The wait is finally over as FinCEN released Frequently Asked Questions to the CDD requirements published on May 11, 2016. In the nearly two years since being published, we have also seen amendments to the requirements on September 29, 2017 ahead of the May 11, 2018 mandatory compliance date.
The 24-page document includes 37 questions ranging from thresholds; identification and verification steps; collection and retention of beneficial ownership information; as well as exclusions and CTR reporting. In a recent survey of our Compliance Masters Group members we discovered that 90% of our members were had not completed their implementation of the Beneficial Ownership rules. Where are you in your implementation? As the deadline approaches these FAQs should assist you in your understanding of the requirements.
The materials for our April 9th webinar, Critical CDD Changes for Beneficial Ownership Rules – Are You Prepared for May 11, 2018?, are currently being updated to include these recently released FAQs. You can sign up HERE.