Is Your AML Program Ready for FinCen’s CDD Rule?

Client alert

On November 21, 2017, the Financial Industry Regulatory Authority (FINRA) issued Regulatory Notice 17-40 which provides guidance on FINRA Rule 3310 (Anti-Money Laundering Compliance Program) in light of FinCEN’s adoption of a final rule on customer due diligence requirements for financial institutions. Under the Notice, firms must review and, as necessary, amend their policies and procedures to explicitly incorporate the Customer Due Diligence (CDD) Rule by May 11, 2018.

With the May 11, 2018, implementation deadline fast approaching, Navigant experts break down the changes and revisions to existing know-your-customer (KYC) and CDD policies, procedures, and controls member firms need to know and implement for AML compliance. Find out what steps need to be taken before the quickly approaching May 11 implementation deadline.

Special thanks to Christopher Roach, who contributed to this report.





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