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FinCEN Public Hearing on the Customer Due Diligence ANPR

On Tuesday, July 31, the U.S. Treasury Financial Crimes Enforcement Network’s (FinCEN’s) held a public hearing on the customer due diligence (CDD) Advance Notice of Proposed Rulemaking (ANPR) that was issued in March 2012.  The hearing included participants from the U.S. Treasury, FinCEN, financial regulators, financial service trade associations, and members of the law enforcement community.  Many hearing attendees and participants shared concerns regarding the potential expansion of the "beneficial ownership" requirements, which would likely impose significant burdens and costs.  FinCEN plans to engage in additional outreach regarding the ANPR at the regional level in the upcoming weeks. 

The Missouri Credit Union Association (MCUA) emphasized that credit unions would face significant compliance challenges and costs if FinCEN proceeds with its ANPR, as outlined in a May comment letter.  


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