The Financial Crimes Enforcement Network (FinCEN), the U.S. agency tasked with issuing anti-money laundering (AML) regulations, recently issued Frequently Asked Questions (FAQ) providing additional guidance on the final regulations that require that banking organizations, securities broker-dealers, mutual funds, futures commission merchants and introducing brokers in commodities (covered financial institutions) identify the beneficial owners of their legal entity customers. The final rule also requires that these covered financial institutions incorporate customer due diligence procedures into their required AML compliance programs.

The FAQs include questions concerning the following subjects:

• Purpose and scope of the rule
• What information to obtain and how to obtain it
• Exemptions, exclusions and limitations
• Required changes to anti-money laundering compliance programs