Is your anti-money laundering program ready for FinCEN’s Customer Due Diligence Rule?
Journal of Investment Compliance
ISSN: 1528-5812
Article publication date: 11 July 2018
Issue publication date: 14 August 2018
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
:Emerald Publishing Limited
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