Blog after blog, commentator after commentator, and everyone else who has an opinion has been repeating the same message – the Biden Administration is going to increase enforcement risks. While these general opinions are correct, a more specific and focused analysis is needed. It is one thing to cite a strong enforcement bent but it is another to watch the key issue – resources. I...
Financial institutions face an important deadline – May 11, 2018 is the effective date for the new customer due diligence regulations governing beneficial ownership requirements. FinCEN provided financial institutions nearly two years to prepare for the implementation date. FinCEN issued comprehensive guidance on the new regulations and has sought to clarify as many issues as possible. (See HERE for Copy). There is no question that...
Chief compliance officers for financial institutions are going to have a rough May 2018. First, on May 11, 2018, the new CDD Rule for beneficial ownership becomes effective. Two weeks later, on May 25, 2018, the EU’s General Data Protection Regulation becomes effective. FinCEN CDD Rule FinCEN’s new Customer Due Diligence rules will have a significant impact on the collection of beneficial ownership information and...
