The Financial Industry Regulatory Authority issued guidance to member firms related to their obligations under enhanced due diligence requirements for financial institutions adopted in 2016 by the Financial Crimes Enforcement Network of the US Department of Treasury. (Click here for background of these requirements in the article “FinCEN Finalizes Rules Requiring Banks, Broker-Dealers, FCMs, Mutual Funds and IBs to Help Verify Beneficial Owners of Certain Accounts” in the May 8, 2016 edition of Bridging the Week.) Under FinCEN’s new requirements, effective May 11, 2018, covered firms including broker-dealers, future commission merchants, introducing brokers and mutual funds must identify the beneficial owners of their legal entity customers. Such entities are currently required to know the identity of each of their legal entity customers, but not necessarily their beneficial owners.