Regulatory Update: FINCEN's New CDD Rule and the New Fifth Prong of the AML Program
Duration: 60 Minutes
The webinar covers the newly released rule relating to the identification and validation of the control and beneficial ownership of legal entities. The new rule expands the requirements of existing AML program by adding the ongoing requirement of control/ownership oversight in the institutions Customer Id Program. From now until its full implementation, May 2018, covered financial institutions are required to develop risk based approaches to ongoing monitoring and implementation of the parties that hold sway over a legal entity that has an account established with it. While there are times in which a third party may be relied upon for such information and monitoring, it is the covered institutions responsibility to identify with whom it does business.
Objectives of the Presentation
Why Should you Attend
- What are the obligations of the covered institution?
- Identifying the control and beneficial parties
- Creating a risk profile of a customer.
- Monitoring the customer risk profile and how it compares to the AML risk profile
- Determining if a change in the profile or the parties is necessary
- Implementing the risk profile into the automated AML/BSA program
You should attend if you are the AML Officer, Customer Onboarding Officer, Compliance and or Legal party that is responsible for the implementation and or development of your institutions Customer ID Program and the related AML/BSA monitoring programs. Through this webinar you will learn how to address this pressing issue and implement it into your CIP and BSA programs.
Who will Benefit
- Sources of information to validate Beneficial/Control Parties
- Determining who are the Beneficial Owners and Control Parties
- How to deal with excluded entities and related parties
- Developing an entity risk profile
- What does the Risk Profile tell and how to use it
- Implementation of the Risk Profile into the BSA AML protocols
- Ongoing Monitoring and Modification of the Risk Profile
- AML/BSA officers
- Managers and Oversight personnel
- Legal and Policy Personnel of Banks
- Insurance Companies
- Credit Unions
- Mutual Funds and Investment Groups
The implementation of the final FINCEN Rule expands the current AML requirements by adding a specific requirement to identify and verify the actual parties in interest. By doing so, it is the obligation of the institution to actually and not constructively know the person or persons that have an interest in and benefit from the relationship with the covered institution.
The expansion of the CIP program expands the current AML/BSA and CIP programs implemented after the USA PATRIOT ACT and places more responsibility on the institution. Automation and an understanding of the underlying principles of the verification of the beneficial and control parties assists in the reduction of perceived risk to the institution and furthers the advancement of restricting illicit funds from being laundered in the covered institution.