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Do you have other burning questions related to BSA/AML compliance?  Are you struggling with Beneficial Owners, Currency Transaction Reports, suspicious activity monitoring, etc.?  If so, just register for the Forum on our website and then start pre-submitting your BSA/AML compliance questions to (please put “July Forum” in the subject line).  We will answer as many of your questions as we can during the allotted hour.

One thing that always generates a lot of questions are the beneficial ownership requirements.  Did you know there are actually two different triggering events when you are required to obtain this information?  The first, is the easy one.  You must get beneficial owner information any time a new or existing entity customer opens up a new account.  The second one; however, is very often missed or overlooked.

Click on the video to listen to Jerod explain more.

Triggering Point

The Bank Secrecy Act/Anti-Money Laundering program beneficial ownership requirements; been around for a couple of years now. Let’s check in and make sure the triggering events are understood by all. We didn’t miss anything along the way. Hi, this is Jared Moyer with Banker’s Compliance Consulting. There’s actually two different triggering points for beneficial ownership requirements. The easy one, any time a new or existing customer opens up a new account. That one you probably all get or if you’re new to the party, that’s the easy one to get. It’s the secondary one that we’re finding when we go out and do training like this or we go and do a review in a financial institution to maybe complete their independent audit. What we’re finding is that secondary triggering point is often getting missed. The rule requires in addition to when a new or existing customer opens up a new account, that also in the normal course of business, if you get information about the customer that’s different than what you already have, that’s also a triggering point.

The other thing about that triggering point is it would also apply to anybody that was initially excluded. In other words, you had accounts that were already on your books in May of 2018 that you didn’t have to retroactively go back and identify, and then ultimately verify beneficial owners on. However, it’s not that they were exempt forever. You see, that secondary triggering point does apply to existing customer relationships. If you have somebody that opened up an account in 2005 and now in 2020, something changes with the structure of that legal entity relationship with you and maybe there’s a new beneficial owner, even though you didn’t call them beneficial owners before that point, that would now be a triggering point for beneficial ownership information to be identified and verified. Even though that existing relationship was exempt in May of 2018.

Make sure your teams aren’t missing that secondary point of beneficial ownership, identification, and verification. This is one of many BSA/AML topics that we tackle throughout our training library at Banker’s Compliance Consulting. I invite you and your team to go check out our library of training options on our website. Better yet, give us a call. Let’s see how we can partner up with you and help you navigate your BSA/AML compliance needs.


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Jerod Moyer

Jerod is the leader of Banker’s Compliance Consulting’s training productions. He is a nationally recognized speaker. Whether it’s a conference, seminar, school, webinar or luncheon, it’s easy to stay engaged when he presents due to the amount of passion and energy he brings to each and every compliance topic. Jerod has spoken on behalf of the American Bankers’ Association, BankersOnline, many state banking associations, private compliance groups and financial institutions. He is a Certified Regulatory Compliance Manager (CRCM) and BankersOnline Guru. Jerod likes to spend his time (between reading regulations and producing compliance training!) relaxing at the lake with his wife and three children, following their activities or engaged in something sports-related!

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