FinCEN adopted a final rule that will make current AML, Customer Identification Program ("CIP") and beneficial ownership rules equally applicable to all types of banks.

As previously covered, the final rule will, among other things:

  • amend the provision that exempts certain financial institutions from the requirement to establish an AML program; and

  • amend the definition of "covered financial institution" to specify that non-federally regulated banks would be subject to the beneficial ownership requirements in the Customer Due Diligence Rule.

The final rule will go into effect 60 days after publication in the Federal Register, and banks that lack a Federal functional regulator must be in compliance with the rule 180 days after its publication.