GDPR Considerations for FinCEN CDD Rule Keren Livneh, Cedric Lindenmann and Elizabeth Leckie LSTA Primary Market Committee Meeting, July 17, 2018 N Y :3 12 48 31 6. 2 2 Potential tensions – EU restrictions vs. US obligations May 25, 2018 Revamped EU rules – General Data Protection Regulation (GDPR) May 11, 2018 US AML...
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
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....
1 FIN-2018-G001 Issued: April 3, 2018 Subject: Frequently Asked Questions Regarding Customer Due Diligence Requirements for Financial Institutions The Financial Crimes Enforcement Network (FinCEN) is issuing these Frequently Asked Questions to assist covered financial institutions in understanding the scope of the Customer Due Diligence Requirements for Financial Institutions, published on May 11, 2016, as amended...
