The Assessment outlines a number of deficiencies relating to customer due diligence (CDD) standards that are also the focus of FinCEN's May 11, 2016 CDD Final Rule ("CDD Final Rule"). The CDD Final Rule formalizes new and existing CDD expectations for banks and certain other financial institutions and adds another minimum requirement to a bank's compliance program. The CDD Final Rule goes into effect on May 11, 2018. Together, this enforcement action and the implementation of FinCEN's CDD Final Rule demonstrate continued and heightened scrutiny of customer and beneficial owner due diligence and the importance of vetting internal conflicts of interest.