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FinCEN's New Customer Due Diligence Rules: What You Need to Know

 

Gain an understanding of the requirements and related developments with FinCEN's new customer due diligence rules.

Banks and other financial institutions are required to identify and verify the identity of beneficial owners of legal entity customers under the Financial Crime Enforcement Networks' (FinCEN) new customer due diligence (CDD) rule. Many bank employees do not fully understand exactly when the CDD rule applies and what actions are required in order to satisfy their regulatory obligations. This topic helps the persons responsible for customer due diligence to understand which customers are covered by the CDD rule and which are excluded from the new requirements, as well as the specific information and documentation requirements for banks. It also guides banks in developing and implementing ongoing anti-money laundering policies to comply with FinCEN rules, including CDD requirements. This information is also critical for legal entity customers to understand their disclosure obligations when beginning new banking relationships, including in corporate transactions.

Agenda

Faculty

Michael T. Gershberg

Michael T. Gershberg

Fried, Frank, Harris, Shriver & Jacobson LLP

  • Partner in the corporate department and U.S. head of the international trade and investment practice, resident in Fried, Frank, Harris, Shriver & Jacobson LLP’s Washington, DC office
  • Practice emphasizes all aspects of international trade and investment law
  • Conducts regular seminars and workshops and authors publications related to the areas of economic sanctions, anti-money laundering, export controls, and foreign investment
  • Member, Law360 International Trade Editorial Advisory Board (2017-2019)
  • Recognized in Chambers USA: America's Leading Lawyers for Business as a Recognized Practitioner in International Trade: CFIUS Experts and also recognized in the Foreign Investment Review chapter of Who’s Who Legal: M&A and Governance
  • J.D. degree, cum laude, Harvard Law School; B.A. degree, magna cum laude, Yale University
  • Can be contacted at [email protected] or 202-639-7085
V. Gerard Comizio

V. Gerard Comizio

Fried, Frank, Harris, Shriver & Jacobson LLP

  • Partner in the corporate department and chair of the banking practice, resident in Fried, Frank, Harris, Shriver & Jacobson LLP’s Washington, DC office
  • Practice emphasizes all aspects of financial services matters
  • Conducts regular seminars and workshops and has written numerous articles analyzing current issues in financial services regulation, and is an author or contributing author of four books on financial services matters
  • Member, Law360 International Trade Editorial Advisory Board (2018-2019); Board of Advisors of the University of North Carolina Law School Center for Banking and Finance; Governing Committee of the U.S. Conference on Consumer Financial Law; Trusts and Investments Subcommittee, American Bar Association, 2005-2006; (Former) Member, Advisory Board, George Washington Law School Center for Law, Economics and Finance; Deputy Chair, Gifts For The Homeless; Member, Board of Visitors, Pace University (Elizabeth A. Haub) Law School
  • Recognized in Chambers USA: America's Leading Lawyers for Business as a leading individual in Financial Services Regulation: Banking (Compliance) and also recognized by Legal 500
  • LL.M. degree, Georgetown University Law Center; J.D. degree, Pace Law School; B.A. degree, Fordham University
  • Can be contacted at [email protected] or 202-639-7450

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