Is your anti-money laundering program ready for FinCEN’s Customer Due Diligence Rule?

Purpose: The purpose of this paper is to bring broker-dealers’ attention to the upcoming deadline for compliance with the Financial Crimes Enforcement Network’s (FinCEN’s) final rule on Customer Due Diligence Requirements for Financial Institutions (the CDD Rule). Design/methodology/approach: The paper explores the origins of the anti-money laundering (AML) requirements and then explores the new CDD Rule requirements as outlined by FINRA Regulatory Notice 17-40. Findings: Firms are likely largely already in compliance with most aspects of the CDD Rule. Practical implications: Most firms likely will not need to make any significant changes to their AML polices. However, for some they will need to evaluate and modify their AML policies and procedures. Originality/value: Practical guidance is obtained from experienced broker-dealer, investment adviser, securities litigation and compliance lawyers.