The Financial Crimes Enforcement Network (“FinCEN”) is issuing these FAQs to assist covered financial institutions in understanding the scope of the Customer Due Diligence Requirements for Financial Institutions,” published on May 11, 2016 (the “CDD Rule”), available at https://www.gpo.gov/fdsys/pkg/FR-2016-05-11/pdf/2016-10567.pdf . These FAQs provide interpretive guidance with respect
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