On April 5, 2021, the Financial Crimes Enforcement Network (FinCEN) issued an Advance Notice of Proposed Rulemaking (ANPRM) soliciting public comment on 48 questions regarding the implementation of the beneficial owner disclosure program established by the Corporate Transparency Act (CTA). This ANPRM is the first of several to come regarding the various provisions of the Anti-Money Laundering Act of 2020, but it is perhaps the most important because the likely impact on the customer due diligence programs of financial institutions.
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