The CTA required FinCEN to promulgate a rule revising the existing 2016 CDD Rule to be consistent with the CTAʼs BOI reporting requirements no later than January 1, 2025. To date, FinCEN has not yet issued a proposed rule. However, once finalized, the rule will affect how financial institutions—including, but not limited to, banks, broker-dealers, and futures commission merchants—are required to (or choose to) conduct due diligence on their customers.
While we currently have limited insight into the substance of these changes, financial institutions are already contemplating how the rule could affect their processes and procedures. We continue to monitor these developments and are assisting financial institutions with preparing for the impending changes.
- Counseled a payment processor about legal obligations under the CTA, including the potential implications of the Access Rule and potential changes to the 2016 CDD Rule
- Advised an insurance company on the implications of the forthcoming CDD Rule for its AML compliance program