1-Hour Program

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On May 11, 2018, a new rule implemented by Financial Crimes Enforcement Network (FinCEN) went into effect that requires U.S. financial institutions to identify certain beneficial ownership information about legal entity customers.  The rule, knowns as the Customer Due Diligence Rule (CDD Rule) applies to all new accounts as well as existing accounts in some circumstances.  Since its implementation date, some banks have taken differing approaches to compliance with the CDD Rule, and significant questions about how the rule applies in certain situations remain unanswered.  In this presentation, Nicole S. Healy, a partner at Ropers Majeski Kohn & Bentley PC, and Adam G. Safwat, a counsel at Weil, Gotshal & Manges LLP, will provide an overview of the CDD Rule and then examine the following issues:

  • How beneficial ownership is determined
  • Open questions regarding indirect beneficial ownership under the rule
  • Verification and information requirements under the rule
  • The intersection of the rule and existing Know Your Customer (KYC) requirements under the Bank Secrecy Act


Program Level: Overview

Intended Audience: Legal, finance and compliance professionals responsible for advising clients regarding AML/KYC issues

Prerequisites: An interest in financial institution KYC and CDD Rule obligations

Advanced Preparation: None


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