NYC Skyline BW

Financial Crimes Enforcement Network (“FinCEN”) CDD Rule

Monthly on selected Mondays at 1:00 p.m. Central Time in two CPE event

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.

The retail cost of the online 2 CPE internal auditor training event is $120 per attendee.

Each attendee will receive 2 CPE Hours (YB). A certificate of completion will be provided.

Program Level of Understanding: Basic
Prerequisites: None
Advance Preparation: None
Delivery Format: Group Internet Based
NASBA Field(s) of Study: Business Ethics
CPE Credits: 2, based on 50 minutes of instruction per hour

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 Items 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.