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Expert Analysis

FinCEN's Customer Due Diligence Expectations: Some Clarity

By Michael Mancusi, Brian McCormally, Erik Walsh and Kevin Toomey (April 9, 2018, 3:55 PM EDT) -- On April 3, the Financial Crimes Enforcement Network issued 37 frequently asked questions and responses with the aim of providing covered financial institutions[1] with a better understanding of the scope of the agency's new customer due diligence requirements, or CDD rule, which become applicable to new accounts beginning on May 11, 2018....

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