Summary of Exceptive Relief from Requirement to Identify and Verify Beneficial Owners at Each Account Opening
Updated 02/24/2026
This summary describes and analyzes the February 13, 2026, order from the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) granting exceptive relief from certain provisions of the 2016 Customer Due Diligence (CDD) Rule. Under the order, covered financial institutions are no longer required to collect and verify beneficial ownership information at each subsequent account opening for an existing legal entity customer. However, covered financial institutions must still comply with all other applicable Anti-Money Laundering / Countering the Financing of Terrorism (AML/CFT) requirements under the Bank Secrecy Act (BSA), including the obligation to conduct ongoing monitoring to identify and report suspicious transactions and, on a risk basis, to maintain and update customer information.
Members Can Download This Tool
Login to Download
Not Yet a Member?
Our members enjoy:
On-demand regulatory guidance hotline – by chat, phone and email – available from anywhere, on any device – 7 am - 6 pm, M-F, Central time
Research time saved daily & weekly across forms, checklists, and trainings — for every regulation
Hours of form-building and branding of bank documents saved; in some cases, even the budget of additional staff
A sounding board for support and reassessment when institutional goals or the regulatory environment changes
Access to attorneys and compliance specialists for risk modelling and decision-making in advance of large business decisions
The knowledge that C/A was created and owned by 30 State Bankers Association to provide bank compliance services to their membership organizations
Find out how a personalized team of attorneys and compliance professionals helps build targeted compliance strategies throughout your institution when you take our Live Membership Demo.