Compliance Action, Volume 23, Number 4
*** From the Editor: Articles uploaded ***
Check back frequently and catch the new content as it is published! Once the issue is complete, the .pdf version will be available (and you will receive an email alert).
- Patti Joyner Blenden, Editor
Bank Secrecy Act (BSA) compliance remains a priority on every single banking regulator’s agenda. Our goal is to provide you with a concise, useful compliance update for your directors, executive team and business line managers.
FinCEN’s beneficial ownership rule (the Rule) requires financial institutions identify and verify important information about all legal entity customers and the individuals who control the entity’s operations and own significant portions (25% or more) of the equity of the organization each time a new account is established. This quick reference guide will help.
Beneficial Ownership Rule Examples
Beneficial ownership is broken into two categories: ownership and control. We psupply a few examples that may provide additional clarity in applying the regulations
CDD Beneficial Ownership Triggering Events (Chart)
FinCEN’s Customer Due Diligence (CDD) regulations mandate that beneficial ownership and the entity’s control person must be identified each time the legal entity customer experiences a triggering event. This chart will help you with some examples of whether a customer interaction is a beneficial ownership trigger.
In the Editor's Opinion
What are We Accomplishing?
I am a staunch supporter of Bank Secrecy Act and the positive impact our compliance can have in helping protect our communities, but I have am concerned about the placement of responsibilities and the effectiveness of the latest regulations.
Compliance Q & A
- Churches and the Beneficial Ownership Rule
- Beneficial Ownership, OFAC, and foreign and domestic PEPs
One of the most controversial pieces of the new Beneficial Ownership Rule (the Rule) is the treatment of accounts that are renewed. FinCEN has made some clarifications.
FFIEC CDD Exam Procedures
- Patti Joyner Blenden
- Board of Advisors:
- John S. Byrne, Esq.
Cliff E. Cook
Julia A. Gliha, MBA
Michael D. Maher
Carl G. Pry
Susan A. Rich
Robert G. Rowe, III, Esq.