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The Atlas Watch List: FinCEN’s CDD Final Rule

25 August 2016
Atlas Fund Services

FinCEN’s Customer Due Diligence (CDD) Final Rule proposes new Beneficial Ownership legislation. The rule impacts financial institutions such as banks, broker-dealers, mutual funds, and investment advisors and other funds currently required to register with the SEC. The rule aims to expand the Treasury’s money laundering vigilance and combat the misuse of vulnerabilities in the US financial system.

Watch List: Expect – Prepare – Act

  1. For all new business accounts: Collect beneficial ownership information. Beneficial owner refers to the person who controls more than 25 percent of a legal and business entity or person
  2. Build/assess customer risk profiles
  3. Conduct on-going monitoring of existing and new accounts
  4. File suspicious activity report (SAR) where appropriate
  5. Establish AML programs which include written policies, procedures and internal controls