The Financial Crimes Enforcement Network (FinCen) issued its final rules under the Bank Secrecy Act relating to customer due diligence requirements. The rules set forth specific customer due diligence requirements for financial institutions to follow. Additionally, the rules impose a new requirement on financial institutions to collect information about and verify the identities of the beneficial owners of a legal entity customer at the time an account is opened, unless specifically exempted or excluded by the rules. Financial institutions can comply with this new requirement by collecting the information on the Certification Form provided in the final rules or by other means which comply with the requirements of the rules.
The final rules are effective 60 days after the date of publication in the Federal Register, which is expected to be published on May 11, 2016. Covered financial institutions must comply with the rules by May 11, 2018.