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Financial Services Law Insights and Observations

FinCEN Releases Summaries of Customer Due Diligence Roundtable Meetings

Anti-Money Laundering FinCEN Bank Secrecy Act

Financial Crimes

This week, FinCEN published summaries of a series of roundtable meetings held to obtain stakeholder feedback on the agency’s proposed rulemaking on customer due diligence. The meetings, held in September and October in Los Angeles, New York, and Chicago, provided a forum to discuss key issues regarding the proposed rulemaking, including (i) the definition of “beneficial ownership,” (ii) practices to obtain and verify beneficial ownership, and (iii) challenges associated with specific products, services, and relationships.