Skip to main content

  • AddRemove
  • Build a Report 
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
  • Alicia K. Kinsey
    T +1 202 263 3356
  • Matthew Bisanz
    T +1 202 263 3434

The Build a Report feature requires the use of cookies to function properly.  Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently.  If you do not accept cookies, this function will not work.  For more information please see our Privacy Policy

You have no pages selected. Please select pages to email then resubmit.