FinCEN's CDD Rule - The New Fifth Prong of the AML

The FinCEN has issued substantial new AML requirements focused on a major expansion of Know Your Customer into what is now Customer Due Diligence, CDD. This webinar will present various aspects of the requirements.

Five years ago FinCEN’s latest major AML requirements came into play, focused on a major expansion of Know Your Customer efforts into what is now Customer Due Diligence, CDD.  It goes far beyond knowledge of the Customer's Legal Entity to the Beneficial Owner of that entity and its Controlling Persons.  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.  Full compliance implementation is required on accounts opened on or after May 11, 2018.

We will have time for questions and will support follow-up emails as well.

• The existing 4 prongs/pillars of AML per the BSA
• Overview of the new 5th prong/pillar
• Triggers that caused this expansion of regulations
• Purposes, per FinCEN
• Three covered entity types
• Customer legal entity
• Beneficial owners
• Controlling persons
• Exclusions
• New Requirements
• Risk profiles
• Updating
• Baseline/normal transactions
• Transaction monitoring

It goes far beyond knowledge of the Customer Legal Entity to the Beneficial Owner of that entity and its Controlling Persons. It is focused beyond the initial customer acceptance step, requiring updating and ongoing monitoring against baseline “normal” activity for the customer type. It is very unlikely that many banks already comply with these requirements.

Commercial banking, Small Business Banking, Private Banking, and International Banking.
New customer processing staff and supervisors
Banks, brokers, other depository institutions

• Fraud
• Compliance and AML
• VP
• Manager
• Director
• Supervisor

Jim George is an independent consultant to banks focusing on issues of fraud. He brings over 25 years as a consultant to major banks in Associate Partner and Principal roles at PriceWaterhouse-Coopers Consulting, IBM Consulting in Bank Risk and Compliance and Andersen Consulting (now Accenture). He has also been SVP Operations for a Fortis-US division providing outsourcing services to the banking industry. 

Jim's work has included projects in fraud investigation, fraud prevention, identity issues, compliance and AML (anti-money laundering). His background includes work in bank operations and payments strategy, reengineering, systems and quality improvement.