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Mar 30, 2012

More Diligent Customer Due Diligence: FinCEN and Beneficial Ownership

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The Financial Crimes Enforcement Network has issued a proposal that could result in a legally binding requirement that banks and securities firms review the beneficial ownership of their corporate customers and of their accounts. Currently an obligation to inquire into beneficial ownership is not mandatory for all customers, but rather recommended for those situations judged to pose a risk of evasion of existing regulations. It appears that this obligation is not good enough, and the result might be a regulation mandating such an inquiry for all customers. Also, such a regulation might be imposed on all financial institutions, not only banks and securities firms.

View full memo, "More Diligent Customer Due Diligence: FinCEN and Beneficial Ownership"

Authors and Contributors

Bradley K. Sabel

Of Counsel

Financial Institutions Advisory & Financial Regulatory

+1 212 848 8410

+1 212 848 8410

New York

Danforth Newcomb

Of Counsel

Litigation

+1 212 848 4184

+1 212 848 4184

New York

Charles Gittleman

Of Counsel

Financial Institutions Advisory & Financial Regulatory

+1 212 848 7317

+1 212 848 7317

New York

Russell Sacks

Partner

Financial Institutions Advisory & Financial Regulatory

+1 212 848 7585

+1 212 848 7585

New York