Subpoena? Don’t freak out! When you receive a subpoena or other legal process, you need to methodically move through a framework for analysis that will aid you in determining what you need to do and how to do it.
Customer due diligence (CDD) is now an explicit legal requirement, just like CIP. A new FinCEN rule adds a new “fifth pillar” that will require extensive modification of your board-adopted BSA program.
In managing vendors for your institution, what are your first, second and third lines of defense? You can delegate authority, but you cannot delegate responsibility. Responsibility and potential liability rest on the financial institution.
Recorded on August 26, 2016
Opening Entity Accounts (updated for the new CDD rules)
This program will help your design and develop procedures to open accounts for legal entities of all types. It will also address how new Bank Secrecy Act rules covering Customer Due Diligence will greatly impact your business accounts procedures.
You may be banking third party payment processors (TPPPs) and in some instances you may not even realize it. Third party payment processors are considered high risk and you must follow BSA guidance in mitigating that risk.