The US Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) published new Customer Due Diligence Requirements for Financial Institutions (the “CDD Rule” which became effective on May 11, 2018. When FinCEN published the CDD Rule, it noted that beneficial ownership identification and verification of legal entities is one of the core elements of customer due diligence (CDD) and should be a requirement of any covered financial institution’s anti money laundering (AML) program. The CDD Rule contains explicit CDD requirements for certain financial institutions under the Bank Secrecy Act and requires those financial institutions to identify and verify the identity of the beneficial owners of certain legal entity customers.
This form of certification has been tailored for syndicated loan transactions and requests the information which covered financial institutions are required to obtain under FinCEN’s customer due diligence rules from legal entity customers about certain of their beneficial owners.
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Membership in the LSTA offers numerous benefits and opportunities. Chief among them is the opportunity to participate in the decision making process that ultimately establishes loan market standards, develops market practices, and influences the market’s direction.