FinCEN Issues Proposed Rule Extending AML and CIP Requirements to All Banks

FinCEN Issues Proposed Rule Extending AML and CIP Requirements to All Banks


By: Michael T. Gershberg, Steven M. Witzel, Joshua D. Roth, Justin A. Schenck

On August 25, 2016, the U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) published a proposed rule that would extend the anti-money laundering (AML) and customer information program (CIP) requirements of the USA PATRIOT Act of 2001 to all banks.  Currently, FinCEN's AML and CIP requirements only apply to banks that are subject to regulation by a federal functional regulator.  The proposed rule also would extend to all banks the customer due diligence (CDD) requirements that FinCEN published in May 2016, on which we reported previously.  See Fried Frank Client Memorandum, FinCEN Issues Final Customer Due Diligence Rule (May 12, 2016).

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