Alert! Implementing New Customer Due Diligence Rules - Two-Part Series

This is the two-part webinar to be held on July 12th and 26th, 2016. To sign up for parts 1 or 2 individually, click on the links in the covered topics below.

FinCEN dropped new rules on May 11th. FinCEN believes 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, 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 customer information.
It’s time to implement new CDD rules for both consumers and legal entities. This two-part webinar will help your financial institution comply with rules for both consumer and legal entity accounts.

Covered Topics:

  • Final rule and changes
  • Part One: Legal Entity Customers
    • 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. 
  • Part Two: Consumers
    • Understand what part of the regulation applies to consumer accounts
    • How to develop new accounts scripts/risk rating and other tools to comply
    • Risk rating and monitoring your consumer customers
    • What are purpose and source questions?
    • How to incorporate into existing procedures
    • How to develop Excel spreadsheets to risk rate your customers
    • Developing alerts and using them for SAR filing
  • What you will receive:
    • Sample Policy
    • Sample Legal Entity Handbook
    • Sample Procedures
    • Script for business and legal entities
    • Script for New account process

Who Should Attend?

BSA Officers, BSA Staff, CIP and Deposit Operations, Branch Personnel, Training, and Compliance