Information on Complying with the Customer Due Diligence (CDD) Final Rule The CDD Rule, which amends Bank Secrecy Act regulations, aims to improve financial transparency and prevent criminals and terrorists from misusing companies to disguise their illicit activities and launder their ill-gotten gains. The CDD Rule clarifies and strengthens customer due diligence requirements for U.S. banks, mutual funds, brokers or dealers in securities, futures commission merchants, and introducing brokers in commodities. The CDD Rule requires these covered financial institutions to identify and verify the identity of the natural persons (known as beneficial owners) of legal entity customers who own, control, and profit from companies when those companies open accounts. 

The CDD Rule has four core requirements. It requires covered financial institutions to establish and maintain written policies and procedures that are reasonably designed to: identify and verify the identity of customers identify and verify the identity of the beneficial owners of companies opening accounts understand the nature and purpose of customer relationships to develop customer risk profiles conduct ongoing monitoring to identify and report suspicious transactions and, on a risk basis, to maintain and update customer information With respect to the requirement to obtain beneficial ownership information, financial institutions will have to identify and verify the identity of any individual who owns 25 percent or more of a legal entity, and an individual who controls the legal entity. 

Exceptive Relief Ruling (FIN-2018-R004): Exceptive Relief from Beneficial Ownership Requirements for Legal Entity Customers of Rollovers, Renewals, Modifications, and Extensions of Certain Accounts 

Ruling (FIN-2018-R003): Extension of Limited Exception from Beneficial Ownership Requirements for Legal Entity Customers of Certain Financial Products and Services with Rollovers and Renewals 

Ruling (FIN-2018-R002): Beneficial Ownership Requirements for Legal Entity Customers of Certain Financial Products and Services with Automatic Rollovers or Renewals 

Ruling (FIN-2018-R001): Premium Finance Cash Refunds and Beneficial Ownership Requirements for Legal Entity Customers 

For more information, please see: 

CDD FAQs (Aug 2020) 

CDD Final Rule 

FFIEC Exam Procedures (May 2018) 

CDD FAQs (Apr 2018) CDD FAQs (July 2016)

 COMPLIANCE

In order to help the government fight the funding of terrorism and money laundering activities and as part of our AML Compliance Program, we are required to obtain and record information and documentation that helps confirm your identity or provide additional information regarding your business. This information may be requested at account opening or during periodic reviews conducted on existing customers. Please be aware of our fees and charges that apply to you, as they may affect your profitability. Our fees and charges are set out on our website, in your membership agreement, and in the contract signed when initiating a buy or sell transaction.