• This guidance clarifies and consolidates existing regulatory expectations for obtaining beneficial ownership information as part of the customer due diligence (CDD) and enhanced due diligence (EDD) processes related to certain accounts and customer relationships.
• A depository institution's CDD/EDD processes should be developed to identify customers who pose heightened money laundering or terrorist financing risks, and should be enhanced in accordance with the institution's assessment of those risks. Conducting appropriate CDD assists an institution in identifying, detecting and evaluating unusual or suspicious activity.
• A financial institution should establish and maintain CDD procedures that are reasonably designed to identify and verify the identity of beneficial owners of an account, as appropriate.
• Beneficial ownership information regarding account relationships provides another tool for depository institutions to better understand and address money laundering and terrorist financing risks, protect themselves from criminal activity, and assist law enforcement with investigations and prosecutions.
• A depository institution may consider implementing beneficial ownership policies and procedures on an enterprise-wide basis.

Distribution:
FDIC-Supervised Banks (Commercial and Savings)

Suggested Routing:
Chief Executive Officer
BSA Compliance Office

Note:
FDIC Financial Institution Letters (FILs) may be accessed from the FDIC's Web site at: http://www.fdic.gov/news/financial-institution-letters/2010/index.html

To receive FILs electronically, please visit http://www.fdic.gov/about/subscriptions/fil.html .

Paper copies of FDIC FILs may be obtained through the FDIC's Public Information Center,

3501 N. Fairfax Drive, Room E 1002, Arlington, VA 22226 (1-877-275-3342 or 703-562-2200).