After four long years in the making, the Financial Crimes Enforcement Network (FinCEN) finalized the Customer Due Diligence Beneficial Ownership rule on May 11, 2016, with the mandatory compliance date set as May 11, 2018. The arduous process included an Advance Notice of Proposed Rulemaking issued in February 2012 and a Notice of Proposed Rulemaking issued in August 2014. Both provided opportunities for commentary. The release of this long-delayed rule may have been motivated in part by the recent disclosure of the “Panama Papers,” which outed a host of wealthy individuals, including celebrities and well-known public officials, who used offshore shell companies to conceal their assets. The Panama Papers brought to light that the United States has become a popular tax haven for money launderers hoping to evade taxes or hide income from other illicit activities.
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