FinCEN's New CDD Rule - The New Fifth Prong of the AML

It goes far beyond knowledge of the Customer Legal Entity to the Beneficial Owner of that entity and its Controlling Persons. It is focused beyond the initial customer acceptance step, requiring updating and ongoing monitoring against baseline “normal” activity for the customer type. It is very unlikely that many banks already comply with these requirements.

The new requirements are formidable. They will impact commercial, small business, private, and international banking areas of the Banks as well as compliance officers and areas currently performing KYC tasks. New research will be required on new entities never addressed before in customer acceptance.