the CTA was enacted in 2021 to address these issues by requiring certain entities to report beneficial ownership information (BOI) directly to FinCEN. The CDD Rule, effective since May 11, 2018, mandates that financial institutions collect BOI as part of their due diligence processes to ensure th...
Customer due diligence (CDD): Under the ‘CDD Final Rule,’ an amendment to the BSA, firms must establish and verify the identities of their customers, including the ultimate beneficial owners (UBOs) of companies, and conduct risk assessments of customer relationships. They must also conduct ongo...
or law enforcement activity; (4) financial institutions using BOI to facilitate compliance with CDD requirements under applicable law; (5) Federal functional regulators acting in a supervisory capacity assessing financial institutions for compliance with CDD requirements; and (6) Treasury o...
The Proposed Rule would not immediately require covered investment advisers to comply with the CIP Rule (i.e., procedures to verify the identity of customers), or the beneficial ownership requirements of the CDD Rule. However, those requirements will eventually be imposed through separate r...