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5th Pillar Of AML Compliance Is Here, But Questions Remain

Law360 (May 11, 2018, 12:37 PM EDT) -- Friday, May 11, 2018, marked the long-awaited compliance deadline for the Financial Crimes Enforcement Network’s customer due diligence rule, the so-called “fifth pillar”[1] of Bank Secrecy Act/anti-money laundering programs. The CDD rule aims to clarify and strengthen customer due diligence by requiring firms to develop customer risk profiles and to collect and verify beneficial-ownership information for legal-entity customers.

The rule applies to covered financial institutions, including broker-dealers, banks, mutual funds and futures commission merchants. Of note to broker-dealers is the Financial Industry Regulatory Authority’s recent amendment...
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