On August 3, 2020, the Financial Crimes Enforcement Network (FinCEN) published three new Frequently Asked Questions (FAQs) regarding Customer Due Diligence (CDD) requirements for financial institutions. The new FAQs clarify the regulatory requirements related to: Obtaining customer information; Establishing a customer risk profile; and Performing ongoing monitoring of the customer relationship. The new FAQs are in addition to those that were published on: July 19, 2016; and April 3, 2018. For further information regarding customer […]

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Why Comply With 2018 CDD Requirement Now

The OCC entered into a Consent Decree with Business Bank of Texas on July 20, 2016 after the OCC initially announced its intentions to issue a Cease and Desist (C&D) Order. Previously, we issued a blog on the Beneficial Ownership FAQs (posted August 18, 2016) which stated that May 11, 2018 was the applicability date for the following requirements: Identification and Verification of Legal Entity Customers; and Requirement to add a new “fifth pillar”: Understand […]

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