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FinCEN Issues FINAL Customer Due Diligence Rules
Monday, May 9, 2016 6:45 AM

Friday, May 6,  FinCEN issued final rules to “clarify and strengthen” customer due diligence requirements under the Bank Secrecy Act for covered institutions, including credit unions. 

FinCEN’s final rules require compliance by May 11, 2018 and contain explicit customer due diligence requirements including a new requirement to identify and verify the identity of beneficial owners of legal entity customers.

The preamble of the final rules provide detailed guidance, including definitions of the following:

  • Covered Financial Institution.
  • Beneficial Owner – Preamble, page 207-8
  • Legal Entity Customer – Preamble, page 209
  • New Account – Preamble, page 35

It is important to note than FinCEN’s final rules include the obligation for financial institutions, including credit unions, to obtain beneficial ownership information on EXISTING members/customers, “when, in the course of normal monitoring, the financial institution detects information relevant to assessing or reevaluating the risk of such customer.” (Preamble, page 28, 93)

For more information, email Barri Hamilton at or call “Information Central” at 800-442-5762 ext. 8515 or direct at 512-853-8515.