Ready, set go! It’s time to implement new CDD rules for legal entities customers. Final rules go into effect on May 11th, 2018. This is a practical approach to implementation of the regulation for legal entities and consumers. 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:
- Customer Identification and Verification
- Beneficial Ownership Identification and Verification
- Understanding the nature and purpose of customer relationships to develop a customer risk profile
- Ongoing monitoring for reporting suspicious transactions and, on a risk-basis, maintaining and updating customer information
- 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
- New Technical Corrections
- Sample Policy
- Sample Legal Entity Handbook with procedures
- Script for consumers 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.
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