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Wisconsin Credit Union Foundation

Newly Released Guidance on CDD Requirements Effective May 11, 2018: FinCEN FAQs

Attend this session to hear vital definitions and requirements for the complex rules based on this new guidance on customer due diligence requirements.

Apr 23, 2018 02:00 PM   -­­  Apr 23, 2018 03:30 PM


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Type of Event
On Demand Webinar

Who Should Attend
  • On Demand
  • Webinars
  • Member Services
  • Lenders
  • Compliance


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


Susan Costonis, CRCM, Compliance Consulting and Training for FIs ​