Understanding FinCEN’s Customer Due Diligence Rule

A panel at PLI’s recent conference on anti-money laundering offered regulator and bank perspectives on the key provisions of the Customer Due Diligence Requirements for Financial Institutions of the Financial Crimes Enforcement Network that took effect one year ago. Peter Hardy, a partner at Ballard Spahr, moderated the discussion, which featured Beverly Jules, officer and head of the Compliance Risk Team within the Large Foreign Banking Organization Function’s Risk and Analysis Department of the Federal Reserve Bank of New York, and Carlos Orel, head of AML risk, products and monitoring at TD Bank. See “How to Leverage AML Tools for ABC Programs” (May 1, 2019).

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