FinCEN Issues 3 FAQs on Customer Due Diligence Requirements

WASHINGTON—The Financial Crimes Enforcement Network (FinCEN) has issued three frequently asked questions on customer due diligence (CDD) requirements for covered financial institutions.

The FAQs, released in collaboration with the federal functional regulators, cover issues related to risk-based procedures, the customer's risk profile, and on-going monitoring.

The FAQs, which also address the requirements and certain flexibilities available under the CDD rule, are in addition to those previously issued by FinCEN in July 2016 and April 2018, NAFCU noted.

For additional information regarding customer due diligence requirements, credit unions are encouraged to visit FinCEN's dedicated CDD webpage. Those with questions or comments regarding the guidance may contact FinCEN's Regulatory Support Section.

Additionally, NAFCU noted it has a webinar available on-demand addressing the legal requirements, implementation challenges, and supervisory expectations for the CDD rule. The association also has a host of other resources available.

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