The Financial Crimes Enforcement Network issued a final rule, to clarify and strengthen customer due diligence requirements, which became effective on July 11, 2016 for which covered financial institutions must comply with by May 11, 2018. Covered financial institutions include banks, brokers or dealers in securities, mutual funds, and futures commission merchants and introducing brokers in commodities. The rules contain explicit customer due diligence requirements and include a new requirement to identify and verify the identity of beneficial owners of legal entity customers, subject to certain exclusions. Covered financial institutions are not presently required to know the identity of the…