FinCEN's New CDD Rule - The New Fifth Prong of the AML

OVERVIEW

FinCEN has issued substantial new AML requirements focused on a major expansion of Know Your Customer into what is now Customer Due Diligence, CDD. It goes far beyond knowledge of the Customer Legal Entity to the Beneficial Owner of that entity and its Controlling Persons. It is focused beyond the initial customer acceptance step, requiring updating and ongoing monitoring against baseline “normal” activity for the customer type. It is very unlikely that many banks already comply with these requirements. Full compliance implementation is required starting May 11, 2018.

WHY SHOULD YOU ATTEND

The new rulesgo far beyond knowledge of the Customer Legal Entity to the Beneficial Owner of that entity and its Controlling Persons. It is focused beyond the initial customer acceptance step, requiring updating and ongoing monitoring against baseline “normal” activity for the customer type. It is very unlikely that many banks already comply with these requirements. Full compliance implementation is required and starts May 11, 2018.

AREAS COVERED

• The existing 4 prongs/pillars of AML per the BSA
• Overview of the new 5th prong/pillar
• Triggers that caused this expansion of regulations
• Purposes, per FinCEN
• Three covered entity types
  • Customer legal entity
  • Beneficial owners
  • Controlling persons
  • Exclusions
• New Requirements
  • Risk profiles
  • Updating
  • Baseline/normal transactions
  • Transaction monitoring
• It starts May 11, 2018you must be doing it then, here is what you will need

LEARNING OBJECTIVES

1. about the FenCIN requirements announced in 2017 and to be fully implemented second quarter of 2018. They are extensive Customer Due Diligence and involve research into entities few banks currently document fully.

WHO WILL BENEFIT

Banking, Brokerage, or any Financial Services company which have AML requirements.

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