Known by some BSA Officers as the fifth pillar of an AML program, the new CDD rule is the most significant change to BSA since the USA PATRIOT Act. The anti-money laundering program rule amendment will require many changes to institutions’ Know Your Customer (KYC) initiatives and Customer Due Diligence (CDD) procedures. Non-compliance can result in severe penalties.
The experts at Banker’s Toolbox have compiled resources and services to help you. Our goal is to arm you with the knowledge you need well before the 2018 beneficial ownership deadline.
Customer Due Diligence Resources
|CDD Action Plan Build a comprehensive action plan to prepare for the new Customer Due Diligence rule.||CDD Best Practices Learn what to implement for the CDD Final Rule in this free webinar.||CDD FAQs & Key Takeaways Understand the key elements to FinCEN's Final CDD rule and access common questions around the CDD requirements.|
|Due Diligence Checklist Access a sample CDD checklist that will help you comply.||CDD Workshops Build an actionable to-do list for the CDD requirements' 2018 deadline.||Understand The CDD Final Rule Get clarification on the CDD Final Rule to ensure your institution is compliant with beneficial ownership.|
|Due Diligence Manager Collect, documents and store the information needed for beneficial ownership.|
What is beneficial ownership?
The new CDD rule requires you to understand the nature and purpose of a customer relationship, and to conduct ongoing monitoring to maintain and update that information.
There is a two prong approach for identifying beneficial owners of accounts through FinCEN's final rule.
- The ownership prong requires you to identify a natural person with a 25% or more ownership of the legal entity.
- The control prong necessitates that you identify a natural person with significant responsibility to control or manage the legal entity.
Even if you are not sure where to start, we can help. Our experts will create a Customer Due Diligence compliance action plan specific to your institution that identifies decisions, timelines, costs, responsibilities and action items you will need to take.
Banker’s Toolbox has more certified BSA subject matter experts than anyone in the industry. Our experts can help analyze your current CIP, KYC and CDD policies, procedures, processes and systems to ensure you are confident and compliant by 2018. However, you must begin now.