FinCEN Promises Leniency as CDD Expectations are Fine-Tuned
In this report, we assess today’s House FinServ Terrorism and Illicit Finance Subcommittee hearing on implementation of FinCEN’s customer due diligence (CDD) rule (see FSM Report LAUNDER121). Addressing the significant industry derisking and clarity concerns raised last month (see Client Report LAUNDER125), FinCEN Director Blanco today said that FinCEN is granting temporary exceptive relief for ninety days for automatically renewing accounts such as certificates of deposits. FinCEN will then determine whether this relief should be permanent. The ruling expires August 9. This move is in addition to what Director Blanco described as a “fine-tuning period” during which FinCEN will work with industry and regulators on examination and compliance expectations.

LAUNDER126.pdf