Customer Due Diligence Requirements for Financial Institutions

SIFMA and its Anti-Money Laundering and Financial Crimes Committee provide comments to the Financial Crimes Enforcement Network (FinCEN) of the U.S. Department of Treasury on a proposal related to customer due diligence (CDD) requirements for financial institutions, Regulatory Identification Number 1506-AB15, Docket Number FinCEN-2012-0001. SIFMA strongly supports FinCEN’s goal of creating greater transparency and harmonizing and clarifying expectations relating to CDD, particularly given the industry’s historical understanding of the anti-money laundering (AML) statutory requirements, which does not fully comport with recent guidance issued by FinCEN. SIFMA shares key comments with respect to each element of the proposed CDD rule.