On 18 August, Crowell Moring issued a client alert saying that FinCEN on 3 August released FAQ regarding customer due diligence (CDD) requirements for covered financial institutions detailed in FinCEN’s “CDD Rule” providing additional detail on conducting due diligence, developing customer risk ratings, and updating customer information. The firm says that the new FAQ do not break any major new ground with respect to the CDD Rule, but can be helpful for financial institutions seeking to set risk-based limits on when specific types of information are needed to determine customer risk. It also says that the  FAQ may provide a valuable reference point for financial institutions explaining – for example, to regulators – the risk-based decisions that have gone into their AML programmes and why not all accounts with certain characteristics need to be treated the same way.

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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