Beneficial Ownership and AML, Sanctions and Anti-Corruption Compliance
Sometimes compliance realities outpace enforcement and regulatory requirements. When it comes to FinCEN’s proposal to implement a beneficial ownership rule for financial institutions (see Here), global financial institutions do not need to worry about the outcome of the FinCEN regulations. Global financial institutions already have to know their (your) customer because of compliance obligations with sanctions and anti-corruption laws. In the anti-corruption context, a financial...