Financial Crimes Enforcement Network; Customer Identification Programs, Anti-Money Laundering Programs and Beneficial Ownership Requirements for Banks Lacking a Federal Functional Regulator Final Rule

Updated 10/14/2020

This tool summarizes the FinCEN’s Interim Final Rule, revising the definition of “bank” to reply all United States banks to comply with BSA, AML, CIP, and CDD Rule, provisions. The following are key takeaways of the changes:

  1. Regardless of whether or which federal functional regulator applies to a bank, no United States bank is exempt from complying with BSA, AML, CIP, and CDD Rule Provisions.
  2. The Final Rule has no effect on banks who had a federal functional regulator, prior to the issuance of the Final Rule.
  3. The Final Rule did not amend or revise any substantive procedures required by the BSA, AML, CIP, and CDD Rules; only definitions of “bank” for the purposes of setting a uniform BSA and AML standard for all United States banks.

Members Can Download This Tool

Login to Download

Forgot password?


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.

Become a Member