How the new CDD Rule will impact AML programs in the years to come
So much time has been spent focusing on the “new” part of the CDD Rule—the beneficial ownership requirement to collect previously uncollected information—that many financial institution’s AML programs view the rule as a “new data collection requirement.” While this is certainly true, collecting information is only half of the rule—and arguably not the important half.
The more pivotal part of the rule in the eyes of FinCEN and other agencies is how that information is ultimately used. To FinCEN, having the correct information is not the goal of AML, though proper record keeping does support law enforcement investigations; the goal of AML is instead to properly detect risky customers conducting suspicious activity
