Notes

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We noted that all account relationships, and not only those which are "accounts" within the CIP rule definition, would be subject to this requirement merely to reflect that all accounts must necessarily be monitored in some form in order to comply with existing SAR requirements. Commentators from the securities industry raised concerns about the proposed fifth Pillar as it would apply in their industry. A few commenters sought clarification of the concept of a customer risk profile, as well as of how the nature and purpose of customer relationships were to be understood for customers of broker-dealers. Commenters also requested that FinCEN clarify the extent of the ongoing monitoring requirement for the securities industry. Any entity whose common stock, or analogue equity interests, are listed on the New York Stock Exchange, American Stock Exchange, or NASDAQ.
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Under the proposed and final rule, covered financial institutions are required to establish and maintain written procedures that are Reasonably designed to identify and verify beneficial owner of new accounts opened for customers of legal entities They must also keep a record of all identifying information, including a description of any document they rely on, any non-documentary methods used, the results of any actions taken, and the resolution of each substantive discrepancy. The proposed rule required financial institutions to obtain from each customer of legal entities a certificate in a prescribed format containing the required identifying information. The final rule is that the institution can obtain the information by using the Certification form or any other means it uses to obtain information from the customer. 슬롯먹튀 has reviewed the comments received by small entities and associations representing them, regardless of whether the comments were referred to the IRFA.
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