April 23, 2019 By: Scott Nance*, Principal, LC Consulting
Recent times have seen an uptick in sanctions enforcement actions, placing an onus on many compliance suites and officers to take head and build a robust sanctions compliance program.
SanctionsAlert.com Sanctions Round Up
May 30, 2018
FinCEN CDD Rule Comes into Effect; FFIEC Issues Guidance for Compliance Suites, including for OFAC Officers
On May 11, 2018, exactly two years after being issued, the Financial Crimes Enforcement Network (“FinCEN”)’s implemented its new Customer Due Diligence (CDD) Rule. This CDD rule enhances CDD requirements and also adds a new requirement for financial institutions to identify, and verify the identity of, the beneficial owners of certain legal entity customers.
OFAC Compliance Officers should take notice, as US Treasury expects financial institutions to use beneficial ownership information not only to comply with AML requirements, but also for compliance with the OFAC regulations.