
Cover Your Bases for New FinCEN Due Diligence Requirements
FinCCEN is expected to release new enhanced due diligence requirements in August. The four key elements the new rule will address are: (1) identifying and verifying member identity; (2) verifying identity of beneficial owners of business entities; (3) understanding the nature and purpose of member relationships; and (4) conducting effective ongoing monitoring for suspicious activity. [6/17/15]