FINANCIAL CRIMES ENFORCEMENT NETWORK Customer Due Diligence Requirements for Financial Institutions Finalized On May 11, 2016, the Financial Crimes Enforcement Network (“FinCEN”) issued its final rules under the Bank Secrecy Act (“BSA”) to strengthen and clarify the customer due diligence (“CDD”) requirements for covered financial institutions such as: bank; brokers or dealers in securities; mutual funds; and futures commission merchants (“FCMs”) and introducing brokers in commodities. Such financial institutions, under the final CDD rules (“CDD Rules”), will now be required to verify and identify the beneficial owners of all legal entity customers during the account opening process. Further, the CDD…