This is a rebroadcast of a session that was recorded in 2017.
When you register for this Webinar, you will receive the following three (3) supplemental handouts-- so rich in content that they alone are worth the program's price!
- (1) CDD Final Rule (full text)
- (2) Sample Proposed CDD Policy & Procedures
- (3) Business Accounts Risk Questionnaire
Ready, set go: It’s time to implement new CDD rules for legal entities customers.
Final rules were issued by FinCEN on May 11th and went into effect July 11th 2016. This is a nuts and bolts webinar on the new regulation and what it will mean to legal entity customers. FinCEN believes that there are four core elements of customer due diligence(CDD), and that they should be explicit requirements in the anti-money laundering (AML) program for all covered financial institutions, in order to ensure clarity and consistency across sectors:
(1) customer identification and verification,
(2)beneficial ownership identification and verification,
(3) understanding the nature and purpose of customer relationships to develop a customer risk profile, and
(4) ongoing monitoring for reporting suspicious transactions and, on a risk-basis, maintaining and updating customerinformation.
- Final rule and changes
- What is a legal entity?
- Who is included and excluded?
- What special rules do we add for beneficial owners?
- Do we have to use the new form?
- Can we gather beneficial ownership information at lower amounts than 25%?
- Do we have to use our same CIP for beneficial owners or can we use a different but similar CIP?
- Are trusts covered? IOLTA?
- How does this work on a multi-tiered business?
- What do we do on charities and nonprofit organizations?
- Does this apply to sole proprietorship accounts?
- How do we risk rate? Monitor?
- Develop new procedures and policies for business accounts
What You Will Receive
- Sample Policy
- Sample Legal Entity Handbook with procedures
- Script for business and legal entities
Who Should Attend
- BSA Officers,
- BSA Staff,
- CIP and Deposit Operations,
- Branch Personnel, Training,
- Compliance, and
- Anyone Who Opens Legal Entity Accounts.