About the Course
Being offered twice a quarter on Tuesdays at 1:00 p.m. to 3:00 p.m. Central Time.
The FinCEN final rule, “Customer Due Diligence Requirements for Financial Institutions” (the CDD Rule) must be followed by all financial institutions.
Learn about the FinCIN CDD requirements and how to be fully compliant.
These FinCIN requirements are extensive and involve research into entities few banks previously documented well within their client base.
The U.S. Department of the Treasury's Financial Crimes Enforcement Network ("FinCEN") issued a final rule requiring the minimum standards for anti-money laundering programs for certain institutions lacking a Federal functional regulator.
It is focused beyond the initial customer acceptance step, requiring updating and ongoing monitoring against baseline "normal" activity for the customer type. Until CDD became a requirement not many banks already complied with these requirements.
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.
The FinCEN requirements are focused beyond the initial customer acceptance step, requiring updating and ongoing monitoring against baseline "normal" activity for the customer type.
This timely, two hour CPE training event is designed for the internal auditor, compliance professional and others who wish to improve their AML and BSA tradecraft skills.
Each attendee will receive 2 CPE Hours (YB). A certificate of completion will be provided.
This Rule requires that banks maintain “appropriate risk-based procedures for customer due diligence,” including understanding customer relationships for developing a customer risk profile” and conducting ongoing monitoring to identify and report suspicious transactions and to maintain and update customer risk information”.
This event provides the tools to design better audit programs to address the Rule.
The purpose of this CPE training event is to cover the internal controls to address this regulation.
CPE Event Highlights
On September 14, 2020, the U.S. Department of the Treasury's Financial Crimes Enforcement Network ("FinCEN") issued a final rule ("Rule") requiring the minimum standards for anti-money laundering programs for certain institutions lacking a Federal functional regulator.
The Rule applies to banks that lack a Federal functional regulator, including, but not limited to, private banks, privately insured credit unions, and certain trust companies. The Rule also extends customer identification program and beneficial ownership requirements to those institutions.
FinCEN noted that it expected that banks lacking a Federal functional regulator "will be able to leverage existing policies, procedures, and internal controls required by other statutory and regulatory requirements to fulfill the obligations set out in the final rule." Banks lacking a Federal functional regulator have 180 days from the day of the Rule's publication in the Federal Register to be in compliance. The rule was published on September 15, 2020, noting a deadline of compliance of March 15, 2021.
This event will expand your knowledge of these new compliance requirements. It will position your institution to have in place the compliance program elements for the Fifth Prong of the AML Program.
Learning Objectives
This CPE event will cover the following learning objectives:
Learn about the FinCIN CDD requirements,
See how to be fully compliant with the requirements,
Understand all the requirements of a compliance program for a retail bank concerning CDD.
Key Issues on the Agenda
The major agenda items within this intense CPE training event are answering:
The original 4 prongs of AML (anti-money laundering) per the BSA (Bank Secrecy Act)
Overview of the 5th prong
Triggers that caused this expansion of regulations
Purposes of the regulation, per FinCEN
Three covered entity types:
Customer legal entity
Beneficial owners
Controlling persons
Exclusions
CDD Requirements
Risk profiles
Updating
Baseline/normal transactions
Transaction monitoring
The difficulty in implementation.
Your Instructor
Jim J. George
Over 30 years of experience as a consultant and advisor to major banks. He was an associate partner and principal at PriceWaterhouse-Coopers Consulting, IBM Consulting in Bank Risk and Compliance, and Andersen Consulting (now Accenture).
