FinCEN has issued an order granting exceptive relief from the longstanding requirement that covered financial institutions (CFIs) identify and verify the beneficial owners of legal entity customers every time a new account is opened. CFIs now need to collect and verify beneficial ownership information once per customer and then update it only when risk or new information warrants. While CFIs must still comply with all other Bank Secrecy Act (BSA) and anti-money laundering and counter-financing terrorism (AML/CFT) obligations, the new order represents an easing of the requirements established by FinCEN’s Customer Due Diligence regulation (the 2016 CDD rule) regarding the diligence CFIs must perform on legal entity customers as part of AML/CFT programs. Companies should consider whether it makes sense to maintain stricter past compliance practices or revise current policies to fit the new rules based on an individualized risk assessment.

