FinCEN Issues New FAQ On CDD Requirements For Covered Financial Institutions
FinCEN issued new guidance on customer due diligence (“CDD”) requirements for covered financial institutions. FinCEN addressed the (i) collection of customer information, (ii) creation of customer risk profiles and (iii) requirement to perform ongoing monitoring of customer relationships.
Customer Information – Risk-Based Procedures
FinCEN clarified that covered financial institutions are not categorically required to (i) collect particular information beyond what is required to develop a customer risk profile, conduct ongoing monitoring and identify beneficial owners, (ii) conduct media […]