Proposed Customer Due Diligence Requirements for Financial Institutions


SIFMA submitted comments to the Treasury Department on a proposal by the Financial Crimes Enforcement Network (FinCEN) regarding customer due diligence (CDD) requirements for financial institutions.

SIFMA strongly supports FinCEN’s goals of creating greater transparency and safeguarding the financial system against illicit use.

However, SIFMA reiterated its previous requests for FinCEN to work with the Securities Exchange Commission (SEC) and Financial Industry Regulatory Authority (FINRA) to publish guidance to assist the securities industry in understanding regulatory expectations for its industry, and to help the industry design programs that comply with expectations. 

This guidance would be beneficial to both regulators and the industry if it sets forth clear examination expectations because it would promote consistency across examination teams and firms.