5th Pillar Of AML Compliance Is Here, But Questions Remain
By Dustin Palmer, Conway Dodge, Elizabeth Bethoney, Christine Livingston and Richard PattersonMay 11, 2018, 12:37 PM EDT
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” 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...