On May 11, 2018, the new Customer Due Diligence Requirements for Financial Institutions (the “CDD Rule” or the “Rule”)[1] are scheduled to come into effect. On April 3 of this year, the promulgator of the CDD Rule, the Financial Crimes Enforcement Network (FinCEN), issued a new Guidance[2] to assist covered financial institutions[3] in understanding the scope of the […]