This guidance - released in unison by several agencies including FinCEN, the SEC, and the Fed – stresses greater customer due diligence (CDD) by firms as part of their overall AML program. The specific emphasis of the guidance is on a firm’s obligation to collect beneficial ownership information for certain accounts and customer relationships, based on perceived heightened risks – particularly those who pose risks for money laundering or terrorist financing. Firms should update their AML program to reflect CDD procedures that identify the beneficial owners of an account, based on the evaluation of risk for an account.

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FrontLine Compliance, LLC is a regulatory compliance consulting firm of former high-level regulatory insiders offering customized services to broker-dealers, investment advisers, investment companies, hedge funds, and insurance company affiliates. Staffed by former SEC and FINRA regulators, and chief compliance officers, FrontLine Compliance provides the kind of industry knowledge, experience and expertise on regulatory issues only available from well-seasoned insiders. For more information about the firm, please visit www.frontlinecompliance.com.

FrontLine Compliance, LLC
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www.frontlinecompliance.com
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