On September 28, 2017, FinCEN issued technical corrections to the final customer due diligence rule that was published in the Federal Register on May 11, 2016. These technical corrections include the following changes to the model form:
- In the first sentence under the heading “What information do I have to provide?” the term “foreign persons” was changed to “non-U.S. persons”.
- In Section II(b), the word “type” was added to “Name, Type, and Address of Legal Entity for Which the Account is being Opened:”.
- In the last columns of SectionII(c) and (d), the term “Foreign Persons” was changed to “Non-U.S. Persons” and the term “Social Security Number” was added after “For Non-U.S. Persons:”.
- In the footnote, the term “Foreign Persons” was changed to “Non-U.S. Persons” and the term “Social Security Number” was added to read “In lieu of a passport number, Non-U.S. Persons may also provide a Social Security Number.”
The correction also reinserts the training element of the AML program requirements for mutual funds, which was inadvertently omitted from the final rule.
These corrections are effective on September 28, 2017. CSi will be updating its solution to include the technical corrections to the model form.