Bankers Toolbox SAMSThe new Customer Due Diligence Rule deadline has passed and hopefully the relief is setting in. FinCEN has stated that there will not be an extension to this deadline, and there is no grey area with regards to regulatory expectations. Ensuring your institution is 100% compliant requires both time and effort, both of which you may not have.

Consider the Fifth Pillar Program Evaluation. This service will give you two very valuable commodities: time and confidence. Find out how you did implementing the new CDD/Beneficial Ownership rule and ensure your readiness for your audit and/or regulatory exam. After all, you worked hard on this program so why not be proactive and make sure all aspects of the requirements have been met?

Fifth Pillar Program Evaluation Breakdown

In the Fifth Pillar Program Evaluation our team will take a comprehensive look at your current situation, evaluate the position you are in and the effort needed to get you to a 100% compliant state. This process involves the following services.


Program Review

Policies and Procedures

Current policies and procedures will be reviewed for complying with the four key elements of the new Beneficial Ownership/CDD rule.


Process Evaluation

Current processes and forms for on-boarding new customer accounts will be evaluated to ensure requirements are met.

Software Check

Enhancement Recommendations 

A review of the host system, including any new accounts interfaces, and AML monitoring software, is completed to ensure compliance with the ruling.


Monitoring Analysis

Customer Due Diligence and Enhanced Due Diligence monitoring processes are analyzed for needed compliance changes.

Gap Analysis

Locate Deficiencies

A written gap analysis is provided uncovering any readiness deficiencies with the new rule, which was effective May 11, 2018.

 The Board

Prepare Leadership

Ensure Board policies and procedures are in alignment, and that the Board is trained as fiduciaries of your institution.

Action Plan

Compliance Readiness

If desired, a written action plan for compliance readiness can be developed and managed by Banker's Toolbox.

Benefits of a Fifth Pillar Program Evaluation

Preparing for beneficial ownership has been stressful. If you are still feeling overwhelmed and you are limited on resources, it is time to seriously consider the Fifth Pillar Program Evaluation. After all, if you don't feel 100% confident that your institution will be compliant at your next audit or exam, this may be your most cost effective and efficient choice.

  • Ensures that your institution is fully compliant by your next audit/exam

  • Feel confident and prepared for your audit/exam

  • Avoid potential enforcement actions, including possible pillar violations

  • Better allocate your resources for critical activities

  • Reinforce an enhanced CDD/EDD program

  • Organize and document your processes, procedures and policies to reference when needed

Click here for more Beneficial Ownership resources or learn about our customer due diligence solution, Due Diligence Manager.