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Is your anti-money laundering program ready for FinCEN’s Customer Due Diligence Rule?

Rick Kuhlman (Bryan Cave Leighton Paisner LLP, St. Louis, Missouri, USA)
Jeff Ziesman (Bryan Cave Leighton Paisner LLP, Kansas City, Missouri, USA)
Carolyn Browne (Bryan Cave Leighton Paisner LLP, St. Louis, Missouri, USA)
Jason Kempf (Bryan Cave Leighton Paisner LLP, St. Louis, Missouri, USA)

Journal of Investment Compliance

ISSN: 1528-5812

Article publication date: 11 July 2018

Issue publication date: 14 August 2018

174

Abstract

Purpose

The purpose of this paper is to bring broker-dealers’ attention to the upcoming deadline for compliance with the Financial Crimes Enforcement Network’s (FinCEN’s) final rule on Customer Due Diligence Requirements for Financial Institutions (the CDD Rule).

Design/methodology/approach

The paper explores the origins of the anti-money laundering (AML) requirements and then explores the new CDD Rule requirements as outlined by FINRA Regulatory Notice 17-40.

Findings

Firms are likely largely already in compliance with most aspects of the CDD Rule.

Practical implications

Most firms likely will not need to make any significant changes to their AML polices. However, for some they will need to evaluate and modify their AML policies and procedures.

Originality/value

Practical guidance is obtained from experienced broker-dealer, investment adviser, securities litigation and compliance lawyers.

Keywords

Citation

Kuhlman, R., Ziesman, J., Browne, C. and Kempf, J. (2018), "Is your anti-money laundering program ready for FinCEN’s Customer Due Diligence Rule?", Journal of Investment Compliance, Vol. 19 No. 2, pp. 42-44. https://doi.org/10.1108/JOIC-04-2018-0039

Publisher

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Emerald Publishing Limited

Copyright © 2018 Bryan Cave Leighton Paisner LLP. All Rights Reserved.

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