Customer Due Diligence Programs
Be sure to JOIN US for our webinar, “Customer Due Diligence Programs & Beneficial Owners”.
The Customer Due Diligence and Beneficial Owner requirements have been in effect for a couple of years now. In that time, we’ve received more guidance, seen institutions go through exams, etc., which all helps to better understand exactly what the regulators are looking for when it comes to your CDD Program. That said, we still see institutions struggling with the requirements.
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Now, if you’re in the BSA/AML management portion at your bank, you’ve been wrestling with customer due diligence now for a couple of years.
Now, we all know that you’re to develop a program where you’re going to establish customer due diligence procedures that will help you determine the nature and purpose of a customer relationship and develop a profile that you can use as a baseline from which to look at their transaction activity and their behavior and see if there’s anything unusual or suspicious going on.
Now that high-level guidance that we received from FinCEN really didn’t give us a lot of marching orders for what exactly this new fifth pillar was supposed to look like when the rubber hits the road in the actual day-to-day operation of the bank. Now, fortunately, there’s been a couple of years now and we’ve received additional guidance. We’ve had a number of cycles where we’ve had reviews and examiners come in and really give some feedback on what this customer due diligence program is supposed to look like.
So we have an update, a new webinar that’s coming out, that we’re going to sit down and we’re going to talk about some of these learnings. High-level, what is a customer due diligence program supposed to look like? How should your customer risk profiles be implemented and when they should be updated and a number of helpful tips and tricks on how to really carve this out and maybe improve the program that you’ve been working on so hard for these last couple of years. Hope you can join us.
Published
2021/02/08
Kevin Edwards
Kevin brings years of experience and a unique perspective on regulatory matters to our clients. A self-proclaimed geek and accredited CRCM, Kevin is also a recovering attorney with experience as in-house counsel for a large regional bank and one of the leading national title insurance providers. For reasons unknown, Kevin decided to leave the safety and serenity of his desk job to seek fortune and glory as a wandering adventurer. Like a bank compliance version of Kwai Chang Caine, The Man with No Name or Don Quixote, he now travels the land seeking to help those in need and righting compliance wrongs, wherever he may find them. Kevin lives in Sioux Falls with his two children, who are surprisingly normal after having endured their father’s vivid imagination for their entire lives. He won’t admit to having any hobbies, because apparently “Regulations never sleep.” (While he does say this in his Batman voice, we’re pretty sure he’s joking.) From the looks of his Facebook page, he likes the outdoors and spending time with his large extended family (who seem like relatively normal people).