FinCEN has issued substantial new AML requirements focused on a major expansion of Know Your Customer into what is now Customer Due Diligence, CDD. It goes far beyond knowledge of the Customer Legal Entity to the Beneficial Owner of that entity and its Controlling Persons. It is focused beyond the initial customer acceptance step, requiring updating and on-going monitoring against baseline “normal” activity for the customer type. It is very unlikely that many banks already comply with these requirements. Compliance implementation is required by May 11, 2018.