On 30 July, the US Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) issued proposed rules to codify and strengthen existing customer due diligence requirements for banks, securities broker-dealers, mutual funds and futures commission merchants and introducing brokers in commodities (“covered financial institutions”). The most significant new requirement in the proposed rule would be the obligation for covered financial institutions to “look-through” certain legal entity customers to identify (and verify the identity of) natural persons who are beneficial owners of such customers. The proposal is open for comment until 3 October.

For further information on FinCEN’s proposed rules, please see our Client Update of 5 August.

Client Update – 5 August