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.

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