On May 6, 2026, FinCEN updated several of its Q&As on Customer Due Diligence Requirements for Financial Institutions Rule to align with the exceptive relief order issued on February 13, 2026. The reissued FAQs also consolidate three sets of previously issued FAQs published in 2016, 2018, and 2020 into a single document.

The order grants covered financial institutions exceptive relief from the requirement to identify and verify the identities of the beneficial owners of legal entity customers at each new account opening. A total of 34 Q&As were updated in relation to the exceptive relief.

The updated FAQs can be found here.

Adam Witmer

Adam Witmer is a speaker, author, and founder of the Compliance Cohort. Adam has taught hundreds of seminars and training sessions to thousands of bankers throughout the United States and teaches on all areas of regulatory compliance. Adam has written five e-books that he never published, hit a grizzly bear while driving in a National Park, and is an award winning photographer and musician (though he no longer takes photos nor plays any instruments). In his spare time, Adam can be found kayaking on the lake, doing taekwondo with his kids, working on his (project) house, or spending time with his family.

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