06-20-18
FinCEN, NFA and Congress: Customer Due Diligence and AML, BSA Developments
Since the Customer Due Diligence Rule (CDD) became effective on May 11, NFA proposed incorporating CDD provisions into their anti-money laundering compliance rules; two House legislators co-sponsored a bill that would increase the reporting thresholds for covered financial institutions and provide a temporary safe harbor for CDD violations; and FinCEN issued a detailed advisory reminding U.S. financial institutions of their obligations concerning senior foreign political figures and suspicious activity reporting.