CDD requirements and resources for companies in the United States of America
CDD requirements and resources for companies in the United States of America

The following Practice Compliance guidance note provides comprehensive and up to date legal information covering:

  • CDD requirements and resources for companies in the United States of America
  • Customer/client Due Diligence (CDD)
  • US State resources

This Practice Note is a one-stop shop for customer/client due diligence (CDD) resources in the USA that saves time and effort by taking you straight to the relevant companies registries for the different States in America.

Company incorporation in the USA is the responsibility of State governments and the information available will vary according to State law.

A legal entity in the USA is usually known as a corporation. Corporations whose shares are traded publicly are registered with the Securities and Exchange Commission (SEC) in Washington which maintains an online register.

Customer/client Due Diligence (CDD)

CDD is a central pillar of the anti-money laundering (AML) and counter-terrorist financing (CTF) regime. CDD requirements underpin the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, (MLR 2017), SI 2017/692, which came into force on 26 June 2017, as amended by the Money Laundering and Terrorist Financing (Amendment) Regulations 2019, SI 2019/1511 from 10 January 2020.

Where the MLR 2017 apply, conducting CDD is an absolute requirement. It is not in itself subject to the risk-based approach. Certain components of CDD however, allow for flexibility and positively require risk assessment.

The component parts of CDD are:

  1. identifying the customer/client, unless the identity of that