The Financial Crimes Enforcement Network (FinCEN) has proposed a rule to strengthen anti-money laundering (AML) customer due diligence (CDD) efforts of “covered financial institutions,” which include banks, broker-dealers, mutual funds, and futures commission merchants and introducing brokers in commodities. The rule would significantly expand the extent that an institution’s CDD efforts look beyond the juridical entity that is, formally, the customer and inquire into its principal shareholders or holders of comparable ownership interests.

This webinar will report on key aspects of the proposed rule and how, if adopted, they will expand existing CDD and customer identification program requirements. We will also explore the implications of the proposed rule regarding the aggregation of transactions for filing currency transaction reports and monitoring of transactions for evidence of structuring or other suspicious activity.   


  • FinCEN’s Notice of Proposed Rulemaking
  • Analysis of differences with the rule as outlined in FinCEN’s Advance Notice of Proposed Rulemaking, issued in 2012 
  • The proposal’s effect on previously articulated “pillars” of AML programs
  • Implications of the proposed rule and the increased AML compliance burden     


12:00 PM - 1:00 PM ET | Webinar


Alan S. Kaplinsky, Practice Leader
Consumer Financial Services Group


Keith R. Fisher
Bank Regulation and Supervision Practice and
Consumer Financial Services Group

Beth Moskow-Schnoll
White Collar Defense/Internal Investigations and
Consumer Financial Services Groups

Joseph J. Schuster
Consumer Financial Services Group

This program is open to Ballard Spahr clients and members of the financial services industry. There is no cost to attend. This program is not eligible for continuing education credits. 

Please register at least two days before the webinar. Login details will be sent to all approved registrants. For more information, contact Lisa M. Prickril at

Program Contact

Lisa Prickril