On September 14, FinCEN issued a final rule that requires minimum standards for anti-money laundering programs for banks lacking a federal functional regulator, including state chartered non-depository trust companies, private banks and non-federally insured credit unions. Under the final rule, these institutions will be required to establish and implement anti-money laundering programs, which must include policies and procedures, a dedicated compliance officer, employee training and an independent audit function. The final rule also extends customer identification program and beneficial ownership requirements to those banks. Banks without a federal functional regulator are currently required to comply with certain Bank Secrecy Act obligations, including filing suspicious activity and currency transaction reports. The final rule becomes effective 60 days after publication in the Federal Register and affected institutions will have 180 days from such publication date to be in compliance.