It’s a dynamic time in the financial crimes world and this is especially true for Customer Due Diligence (CDD) regulations, as demonstrated by the following recent developments:

1. The leak of the Panama Papers highlighted well-known fears in the financial compliance world that the use of shell companies obfuscates the true ownership of the entities.
2. Financial Institutions (FI) are working to comply with the new rules on beneficial ownership.
3. The Financial Crimes Enforcement Network (FinCEN) released the “Customer Due Diligence Requirements for Financial Institutions; Final Rule” on May 11, 2016.