Description (NEWLY ADDED)
On April 3, 2018, the Financial Crimes Enforcement Network (FinCEN) issued
long-awaited frequently asked questions (FAQs) regarding its new customer due
diligence (CDD) requirements. The revised FAQs were released 28 working days
before the CDD rules become effective on May 11, 2018. How will these new
clarifications impact your CDD implementation plan? The 24-page document
includes 37 questions and answers including coverage thresholds, identification
and verification steps, collection and retention of beneficial ownership
information, exclusions, and CTR reporting. Attend this session to hear vital
definitions and requirements for the complex rules based on this new guidance.
Learning Objectives
- Review of important definitions and clarifications in
the new FAQs
- Nineteen of the thirty-seven questions mention risk. Learn
about the expectations for measuring risk- related triggers based on the new
guidance
- Options for the certification process using the form in
Appendix A of the rule
- Learn how and when re-certification of beneficial
ownership is required
- How to correctly confirm pre-existing CIP
information for legal entities
- Satisfy record retention requirements
- Coverage of automatically renewable CDs as accounts
- Options to
handle renewed loans and CDD information for multiple accounts
- Learn when
subaccounts are considered new accounts
- Training tips to help employees
understand the impact of this guidance
Speaker
Susan Costonis, CRCM, Compliance Consulting and Training for FIs