Alert May 15, 2012

FinCEN Extends Comment Period on Proposed Rule Regarding Customer Due Diligence Requirements

The Financial Crimes Enforcement Network (“FinCEN”) extended the comment period from May 4, 2012 to June 11, 2012 on FinCEN’s advanced notice of proposed rulemaking (the “ANPR”) proposing to strengthen existing customer due diligence requirements and to require expressly that covered financial institutions (including banks, brokers or dealers in securities, mutual funds, futures commissions merchants and introducing brokers in commodities) identify, with limited exceptions, beneficial owners of their account holders.  See the March 6, 2012 Financial Services Alert for a discussion of the ANPR.