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.