BSA Compliance Series:
FinCEN’s CDD Rules & BSA Compliance: Why Preparing Now for the Fifth Pillar is Critical
Wednesday, February 8, 2017
12:00 pm – 1:30 pm PT
1:00 pm – 2:30 pm MT
2:00 pm – 3:30 pm CT
3:00 pm – 4:30 pm ET
This webinar will address two issues regarding the fifth pillar of the new customer due diligence rules. First will be an overview of changes that mandate additional procedures to “understand the nature and purpose” of the legal entity relationship to develop a “reasonable” risk profile. The second will be how to conduct ongoing monitoring to identify and report suspicious transactions and, on a risk basis, maintain and update accountholder information. FinCEN provided ample lead time to navigate these substantial changes to policies, procedures, forms, and effective monitoring processes. Regulators will expect financial institutions to have an implementation plan well in advance of the May 11, 2018, effective date to meet these challenges.
Continuing Education: Attendance verification for CE credits upon request
- How to comply with the four core elements of the CDD rules
- Customer identification and verification
- Beneficial ownership identification and verification of a “legal entity”
- Understand the nature and purpose of customer relationships to develop a customer risk profile
- Ongoing monitoring for suspicious transactions, and, on a risk basis, maintaining and updating customer information
- Documenting the two-prong test for beneficial ownership and control of a legal entity
- What does the frontline and lending staff need to know?
- How will BSA staff, operations, and the audit function support the new rules?
- What new internal controls will be required?
- Tips to identify suspicious activity, beginning with establishing an activity baseline at account opening
- Four unique sources of risk for legal entity accounts, including terrorist financing, money laundering, business identity theft or fraud, and business account takeover
- Events that may trigger an update to the risk profile for both loan and deposit accounts
- TAKE-AWAY TOOLKIT
- CDD checklists under the new rules
- Risk profile template
- Sample CDD policy
- Procedures template for identifying and verifying beneficial owners
- Employee training log
- Quiz you can administer to measure staff learning and a separate answer key
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WHO SHOULD ATTEND?
This informative session is designed for BSA officers, BSA personnel, deposit operations staff, loan operations employees, loan officers, risk managers, compliance officers, new accounts staff, and auditors.
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