Compliance: 6 months until FinCEN’s CDD rule is effective

Credit unions now have less than six months to come into compliance with the Financial Crimes Enforcement Network’s (FinCEN) Customer Due Diligence (CDD) rule, effective May 11, 2018. CUNA has developed a number of tools to assist credit unions, including a CDD checklist, final rule summaryand CDD compliance chart.

The rule includes provisions that address identifying the beneficial owners of legal entity accounts and financial institutions’ anti-money laundering (AML) programs.

New beneficial owner requirements include:

  • Identification and verification of beneficial owners of legal entity members;
  • A new certification form requirement;
  • Written procedures;
  • Record keeping; and
  • Record retention.


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