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Legal Update

Observations on Recently Issued FinCEN Guidance on the Customer Due Diligence Rule

2 September 2016
Mayer Brown Legal Update

In July, the US Treasury’s Financial Crimes Enforcement Network released new guidance related to its recently adopted customer due diligence rule. While largely reiterating the rule’s requirements, in several cases the guidance provides additional clarity, particularly with respect to non-statutory trust accountholders.

The customer due diligence rule requires financial institutions to obtain beneficial ownership information from legal entity customers. Compliance is not required until mid-2018, but many financial institutions are beginning to prepare their implementation plans, as the rule will require significant time and resources to modify existing systems, procedures and personnel training.


  • Thomas J. Delaney
    T +1 202 263 3216
  • Matthew Bisanz
    T +1 202 263 3434
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