You are exactly 51 days from mandatory compliance with the CDD regulation. At a minimum, compliance entails adding this “fifth pillar” to your BSA program. That requires an amendment of your board adopted BSA/AML policy.
You should have already:
• explained the new regulation to the board in general terms (noting the discussion in the board minutes) months ago,
• set the compliance date for your bank (on or before May 11), and
• gotten approval of the policy amendments (addition of CDD and possible revision of CIP) on the board agenda for a regular meeting prior to the effective date.
Banks are legitimately complaining that some key decisions may be affected by an as yet unpublished Q & A from FinCEN and, to a lesser extent, examination procedures from the FFIEC. However, there is no assurance that either will be published before May 11. Banks need to go with what they have in a timely fashion; the FFIEC and FinCEN do not have a deadline, but banks do.
You can note in the board minutes that the policy and its implementing procedures may need to be revised based on expected regulatory pronouncements. If you have voluntarily enhanced the compliance requirements of the regulation, I suggest you itemize those enhancements, drawing them to the attention of your bank’s management.
In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.