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From the Editor: Good for Law Enforcement, Not Too Onerous for Banks

By Kieran Beer

The proposed customer due diligence rule that was released July 30 was notable for what it didn't require, perhaps even more than for what it did. In its advance notice of proposed rulemaking, the Financial Crimes Enforcement Network (FinCEN) outlined its then-potential plans for regulations meant to shine daylight on the murky world of corporate ownership by tasking banks with identifying beneficial owners. But the notice of proposed rulemaking (NPRM) did not: ·         Make banks responsible for verifying that the individuals who claim corporate ownership are the actual owners, although it does require verification of their identities consistent with existing...

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