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LSTA Newsletter: May 18, 2018

This week we cover The End of Risk Retention, Lessons Learned form the Risk Retention Saga, FinCEN Market Advisory and Bankruptcy Roundup

LSTA Publishes Market Advisory on FinCen’s Customer Due Diligence Rule

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.

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