Beneficial Ownership, Customer Due Diligence and The New Rules




Course description:

FinCEN issued the Customer Due Diligence (CDD) Rule last year to amend existing BSA regulations in order to clarify and strengthen customer due diligence requirements for certain financial institutions. Along with outlining explicit customer due diligence requirements, the rule also enacts a new requirement for these financial institutions to identify and verify the identity of beneficial owners of legal entity customers, subject to certain exclusions and exemptions.

In this session, we will review the CDD Rule and the new requirements issued by FINCEN, along with sharing information and procedures for the beneficial ownership rule.

Why should you attend:

FinCEN’s new CDD rules require legal entity customers to identify and verify the identities of their beneficial owners when they open an account. FinCEN Published Proposed Beneficial Owner Information Access Rule On December 16, 2022, with an effective date of January 1, 2024.

Learning objectives:

  • Understand what beneficial ownership is and why we have to know this
  • Demonstrate how to determine beneficial ownership
  • Understand what the new procedures are for determining beneficial ownership
  • Background on the new Customer Due Diligence Beneficial Owner rule
  • Beginning the project – how to start, where to start
  • Creating a project plan
  • Who should be involved in the Customer Due Diligence Beneficial Ownership project?
  • Creating flow charts to make out the current process and future process
  • Examples of what decisions points are needed
  • How to train and who to train
  • How to implement the project
  • Higher-risk customer types that need frequency monitoring in comparison to lower-risk customer types that need infrequent monitoring
  • BSA policy and program requirements and changes
  • Regulatory requirements
  • Types of accounts to include in CDD monitoring
  • Board and senior management expectations and responsibilities
  • Baseline determination of “normal” vs “suspicious” activity
  • Development of an initial customer risk profile
  • The threshold for updating a customer profile
  • Connecting the dotted line between unusual CDD activity and the filing of a SAR
  • CDD and its impact on the bank’s annual BSA risk assessment
  • How to avoid examination and audit findings
  • Record retention
  • Transactional internal testing

Complimentary Handouts:

  • Beneficial Ownership Participant Guide
  • Sample Beneficial Ownership form at account opening

Who Will Benefit:

  • BSA Officers
  • BSA Staff
  • CIP and Deposit Operations
  • Anti-Money Laundering Officers
  • Internal Auditors
  • Financial Officers
  • Front Line Staff
  • Risk Officers
  • Operational Managers
  • Branch Personnel
  • Training
  • Compliance
  • Staff with roles and responsibilities in BSA / AML management and oversight
  • Anyone who opens legal entity accounts
  • New Accounts Representative
  • Banking Operations Managers
  • Payments Directors
  • Compliance Officers and Managers
  • Risk Management staff
  • Account Managers
  • General Counsel

About the instructor:

Doug Keipper is Vice President, BSA/AML Officer at BankSouth.

  • Certified Anti-Money Laundering Specialist (CAMS) since 2005
  • Bank Secrecy Act Officer for a billion-dollar bank
  • Sold BSA software for eight years
  • Teaching anti-money laundering classes since 2008
  • Has talked with over 500 BSA officers throughout the USA and Caribbean
  • Spent over 20 years in retail banking, wholesale mortgages, and financial services

Additional information


USB, Recording


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