Removing Barriers Blog

FinCEN Issues Final Rule on Customer Identification Programs, Anti-Money Laundering Programs, and Beneficial Ownership Requirements for Banks Lacking a Federal Functional Regulator

FinCEN is issuing a final rule implementing sections 352, 326 and 312 of the PATRIOT Act and removing the anti-money laundering program exemption for banks that lack a Federal functional regulator, including non-federally insured credit unions. This Final Rule requires minimum standards for anti-money laundering programs for banks without a Federal functional regulator to ensure that all banks, regardless of whether they are subject to Federal regulation and oversight, are required to establish and implement anti-money laundering programs, and extends customer identification program requirements and beneficial ownership requirements to those banks not already subject to these requirements.

This Final Rule is effective November 16, 2020. The compliance date for anti-money laundering programs, customer identification programs, and beneficial ownership requirements for banks that lack a Federal functional regulator is March 15, 2021.