In “Five Areas of Focus for the New CDD Rule” (ACAMS Today, 15 Aug. 2016), the K2 Intelligence Regulatory Compliance team discusses the new customer due diligence (CDD) rule for financial institutions that the U.S. Treasury Department and the Financial Crimes Enforcement Network (FinCEN) finalized on11 May 2016. The team notes that, “The rule, to take effect in 2018, adds a “fifth pillar” of CDD. Institutions will now not only need to designate a compliance officer; establish policies, procedures, and controls; train employees; and undergo independent testing, but they will also need to identify individuals owning 25 percent or more of an entity holding an account and an individual with ‘significant responsibility’ to control it, with some exceptions.” They add, “The rule applies to all new customers and implies that banks may wish to apply it to existing customers sooner rather than later.”

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This article was originally published on, a publication of the Association of Certified Anti-Money Laundering Specialists (ACAMS) © 2016 – | Reprinted with permission.