In May 2016, the US Treasury’s Financial Crimes Enforcement Network (FinCEN) published final rules (Rules) that will strengthen customer due diligence requirements for covered financial institutions, including mutual funds (but not registered investment advisers or registered transfer agents). The Rules will require mutual funds to identify and verify the identity of beneficial owners of legal entity customers, subject to certain exemptions.
In the August issue of The Investment Lawyer, investment management partner Sarah Clinton (Boston) discusses key points of the final rules as they relate to mutual funds. The article includes an overview of the new rules and existing regulations, key definitions, beneficial ownership identification and verification, requirements for mutual funds’ AML compliance programs, and broader implications of this regulation.
Financial institutions have until May 2018 to comply with the new Rules.
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