ACAMS Public Documents

Comment Letter to FinCEN on ANPRM for CDD 

05-03-2012 20:03

This is in response to the February 29, 2012 advanced notice of proposed rulemaking on customer due diligence for financial institutions. The Financial Crimes Enforcement Network (FinCEN) issued the ANPRM to solicit public comment on a wide range of questions pertaining to the possible application of an explicit customer due diligence (CDD) obligation on financial institutions, including a requirement for financial institutions to identify beneficial ownership of their accountholders.

ACAMS is filing this comment letter on behalf of individual members who have asked questions regarding the parameters of the ANPRM during a webinar we held on April 25, 2012 and included 1500 sites. ACAMS is not taking a position on the request; we are simply providing information to FinCEN from affected ACAMS members.

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Comment Letter to FinCEN on ANPRM for CDD   162K   1 version
Uploaded - 05-03-2012
This is in response to the February 29, 2012 advanced notice of proposed rulemaking on customer due diligence for financial institutions. The Financial Crimes Enforcement Network (FinCEN) issued the ANPRM to solicit public comment on a wide range of questions pertaining to the possible application of an explicit customer due diligence (CDD) obligation on financial institutions, including a requirement for financial institutions to identify beneficial ownership of their accountholders. ACAMS is filing this comment letter on behalf of individual members who have asked questions regarding the parameters of the ANPRM during a webinar we held on April 25, 2012 and included 1500 sites. ACAMS is not taking a position on the request; we are simply providing information to FinCEN from affected ACAMS members.