Last week, the FFIEC issued new examination procedures on the “Customer Due Diligence Requirements for Financial Institutions” rule finalized by FinCEN on May 11, 2016. The new examination procedures replace those in the current “Customer Due Diligence — Overview and Examination Procedures” section of the FFIEC’s Bank Secrecy Act/Anti-Money Laundering Examination Manual. In addition, a new overview and examination procedures were developed for the beneficial ownership requirements for legal entity customers. The revised procedures were issued on May 11, 2018, the day the rule became effective.

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