The OCC entered into a Consent Decree with Business Bank of Texas on July 20, 2016 after the OCC initially announced its intentions to issue a Cease and Desist (C&D) Order. Previously, we issued a blog on the Beneficial Ownership FAQs (posted August 18, 2016) which stated that May 11, 2018 was the applicability date for the following requirements: Identification and Verification of Legal Entity Customers; and Requirement to add a new “fifth pillar”: Understand […]
Tag: Beneficial Ownership
FINCEN BENEFICIAL OWNERSHIP Q’S AND A’S.
On July 19, 2016, FinCEN issued FIN-2016-G003 with the following subject line: Frequently Asked Questions Regarding Customer Due Diligence Requirements for Financial Institutions (“FAQ”) FinCEN’s stated purpose in issuing these FAQs was to assist covered financial institutions in understanding the scope of the Customer Due Diligence (CDD) requirements for financial institutions which were published in the Federal Register on May 11, 2016 and which become fully effective on May 11, 2018. The May, 2016 CDD […]