FinCEN Requests Comments on Due Diligence Programs for Correspondent Accounts for Foreign Financial Institutions and for Private Banking Accounts
On September 29, 2020, the Financial Crimes Enforcement Network (FinCEN) published in the Federal Register a 60-day notice to renew the Office of Management and Budget (OMB) control number assigned to the regulatory requirements to conduct due diligence and enhanced due diligence over foreign correspondent accounts and private banking accounts. The notice is required to give the public an opportunity to comment on existing regulatory requirements and burden estimates. As a result of recommendations from OMB, in the notice, FinCEN proposes for review and comment a methodology to expand the scope of future estimates of cost and time for purposes of the Paperwork Reduction Act to be more granular in the estimates of resources expended to comply with these regulatory requirements. The notice requests feedback from industry on or before November 30, 2020. FinCEN encourages the public to review these notices and provide comment.