[20181031]IF11014_财政部新客户尽职调查规则的实施：迈向实益所有权透明度的一步？.pdf

https:/crsreports.congress.gov Updated October 31, 2018Implementation of Treasurys New Customer Due Diligence Rule: A Step Toward Beneficial Ownership Transparency?Introduction Since May 11, 2018, U.S. financial institutions are required to comply with a U.S. Department of the Treasury rule aimed at cracking down on illicit capital flows through accounts held by anonymous corporate vehiclesoften called “shell companies.” The Treasury rule, known as the customer due diligence (CDD) rule, amends existing CDD requirements for certain financial institutions, a key element of know-your-customer obligations. Although the new CDD rule was finalized two years ago (May 11, 2016), the Financial Crimes Enforcement Network (FinCEN), a Treasury bureau, delayed implementation until 2018. The CDD rules implementation is the culmination of a multi-year effort by the federal government to address money laundering and tax evasion risks posed by shell companies whose beneficial ownership is not transparent. Although the rule represents a step toward addressing criticism of current beneficial ownership transparency practices in the United States, some policymakers continue to debate whether legislati