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"
