Fenergo: 13 Points of Clarification for FinCEN Final Rule

A mere five weeks from implementation of its FinCEN Final Rule (CDD) on May 11th, 2018, FinCEN has released their eagerly awaited frequently asked questions (FAQ) document, providing additional guidance under 37 questions pertaining to the rule. This guidance provides much-needed clarifications on a number of fronts, including beneficial ownership thresholds, account definitions, risk-based monitoring, treatment of non-US listed entities and pre-existing customers. I’ve explored several of

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