Two dates are relevant. The regulation is effective July 11, 2016. So, if you implement a compliance effort before that date you will be judged on whether your program complies with your own policies and procedures. After that date, your effort will be judged by whether it actually complies with the regulation.
The other date is the “Applicability Date,” an unfamiliar term to many people. In effect, it is the date on which compliance is mandatory, May 11, 2018.
Learn more about Ken’s webinar Customer Due Diligence! New BSA Regulation
Before the regulation was finalized, attempting to comply “early” was a poor compliance management decision because critical details were unknown. Now that the regulation is final; i.e. the minutiae of compliance requirements are clear, putting this mechanism in place now rather than two years from now could be a reasonable, efficient response.