US takes a measured stride on beneficial ownership

The Financial Crimes Enforcement Network first proposed extension of existing customer due diligence obligations to identification of beneficial owners of accounts in covered US financial institutions in February 2012. After protracted consultations with industry a notice of proposed rulemaking (NPRM) was published at the end of July. Franca Harris Gutierrez, Sarah Pfuhl, Boyd M. Johnson III, Katrina Carroll and Elijah M. Alper of WilmerHale look at how much more financial institutions will need to know about who owns or controls some of their corporate and other legal entity customers.