Customer Due Diligence/Beneficial Owners: Updating Customer Information
The Customer Due Diligence (CDD) and Beneficial Owner (BO) requirements are not a one and done. In other words, you must continuously update the information over time if/when something changes. For example, if you become aware that a beneficial owner of a legal entity customer has passed away, that should trigger you to update and recertify the beneficial ownership information for that customer. This can be tricky; however, as this type of information doesn’t usually get uncovered by your BSA team, rather it’s detected by your frontline (tellers, new accounts, lenders, etc.) as they interact with customers. Thus, it is very important to train your frontline personnel to understand what types of information can trigger the need to update CDD/BO information and where/to whom they need to forward that information. Failure to do so can result in problems with your overall BSA program.
Kevin explains more in the video.
2025/01/15
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).