Treasury's Financial Crimes Enforcement Network is drafting a new rule that will restate and potentially expand banks' obligations to identify beneficial owners of client entities, even as the current administration has rolled back most corporate beneficial ownership reporting requirements under the Corporate Transparency Act. The forthcoming rule signals that FinCEN intends to maintain robust know-your-customer standards at the financial institution level regardless of broader deregulatory trends.
For Armada, both the traditional repo desk — dealing with hedge funds, asset managers, and MMFs — and the crypto desk — serving family offices, miners, and market makers — will be subject to whatever new CDD standard FinCEN finalizes. If the rule tightens beneficial ownership verification requirements, Armada's onboarding workflows, counterparty documentation, and GMRA/MRA representations may need updating. Early engagement with the rulemaking process and a gap analysis against current procedures is warranted before a proposed rule is formally published.