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FinCEN Issues Final Rule applying certain AML rules to Banks Lacking a Federal Functional Regulator

September 16th | 2020



FinCEN recently adopted a final rule that will make current AML, Customer Identification Program ("CIP") and beneficial ownership rules applicable to all types of banks. The final rule will, among other things:

  1. Amend the provision that exempts certain financial institutions from the requirement to establish an AML program; and

  2. Amend the definition of "covered financial institution" to specify that non-federally regulated banks would be subject to the beneficial ownership requirements in the Customer Due Diligence Rule.

The final rule will go into effect 60 days after publication in the Federal Register, and banks that do not have a Federal functional regulator must be in compliance with the rule 180 days after its publication. As a practical matter, this means that many banks will have six months to implement an adequate AML program.

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