All attendees will receive a sample checklist for meeting the new Customer Due Diligence and Beneficial Ownership requirements.
The Financial Crimes Enforcement Network (“FinCEN”) issued its final rule on beneficial ownership with respect to customer due diligence ("CDD") requirements in May 2016. This rule requires Financial Institutions to adopt due diligence procedures that ensure the bank or credit union verifies and identifies the beneficial owner(s) of the legal entity each time a new account is opened.
The new rule unofficially incorporates CDD into a new fifth pillar for BSA/AML.
The challenge for FIs is determining how to incorporate these CDD changes within preexisting products and systems. In other words, how can you modify the network that current supports your CDD and Bank Secrecy Act ("BSA") monitoring processes in the most efficient manner and at the lowest cost?
The May 11, 2018 FinCEN applicability deadline for these changes is rapidly approaching. There are few anti-money laundering (AML) products that have developed a functionality enhancement to support beneficial ownership. It can take months to implement an enhancement or product because time is required to build the interface and/or upgrade the product to comply with the new CDD rules.
If you're behind schedule, this is the program for you, as you'll learn how to get back on track and be compliant by the deadline.
- Two-Prong Approach to Beneficial Ownership.
- Conducting OFAC scans on Benefiical Owners.
- Identifying & verifying the identity of your customers.
- Identifying & verifying the identity of beneficial owners with 25% or more equity interest of your legal entity customers.
- Understanding nature & purpose of customer relationships
- Conducting ongoing monitoring to maintain and update customer information & to identify & report suspicious transactions
- Establish and maintain written procedures that incorporate the identification of beneficial owners of legal entity customers into their AML compliance program
- Review FinCEN's certification form in Appendix A of the new rule
- Discuss a list of exclusions in the new rule
- Discover how to run reports to look for any transactional patterns and amounts that deviate from that “expected level of account activity.”
Who Should Attend?
This rule applies to all accounts including checking, savings, certificates and loans. Therefore, anyone at your Institution who is invovled in opening accounts and lines of credit must understand the new requirements.
This informative session will therefore be especially beneficial to the following positions:
- BSA/AML Staff
- New Accounts Personnel
- Lending Officers
- Retail Sales Staff
- Customer Service Representatives
- Business Development Officers
- Risk Management Staff
- Compliance Officers