From: jeffrey E. <[email protected]> Sent: Monday, May 23, 2016 4:31 PM To: Shahzad Shahbaz Subject: fyi The regulations <https://www.fincen.gov=> t=at would require that banking organizations, securities broker-dealers, mutual funds, futures commission merchants and introducing brokers in commodities ("covered financial institutions") identify the=beneficial owners of their legal entity customers. The final rule also requires that these covered financial institutions incorporate customer due diligence procedures into their required AML compliance programs. Cer=ain US financial institutions must maintain AML compliance programs and a subset of those financial institutions, the covered financial institutions, also must implement a written risk-based customer identification program ("CIP") that, at a minimum, includes=obtaining, verifying and retaining certain information regarding each new customer, whether the customer is a natural person or an entity. Persons exempt from the CIP procedures include governmental agencies and regulated financial institutions. The Financial Ac=ion Task Force <http://www.f=tf-gafi.org/home/> (FATF), the international AML standards setting organization, recommends that countries "should ensure that there is adequate, accurate and timel= information on the beneficial ownership and control of legal persons that can be obtained or accessed in a timely fashion by competent authorities." The FATF defines a "beneficial owner"=as the natural person(s) who ultimately owns or controls a customer and/or natural person on whose behalf a transaction is being conducted. It also includes those persons who exercise ultimate effective control over a legal person or arrangement. Other international organizations also endorsed a requirement to identify beneficial owners. Current CIP=compliance with FATF standard Current CIP procedures are not required to include identification of the beneficial owners for every legal entity, e