You need a full understanding of FinCEN's two significant guidance documents and the 63 FAQs they contain, in order to fully comply with the regulations on Beneficial Ownership Requirements for Legal Entity Customers and the codification of a &q
Recorded on April 23, 2018
Just the FAQs — FinCEN’s Guidance on Beneficial Ownership and Customer Due Diligence
Banks simply cannot comply with FinCEN’s 2016 Customer Due Diligence Requirements for Financial Institutions rule, with its addition of Beneficial Ownership Requirements for Legal Entity Customers and codification of a “five pillar” requirement for f
When your customer passes away, there are issues that must be addressed. Family members left behind often need to act without knowing what they can and cannot do with the decedent’s account or with checks payable to the deceased. They need guidance.
FinCEN says that “Banks specifically are expected to “obtain information at account opening sufficient to develop an understanding of normal and expected activity for the customer’s occupation or business operations.” In short, to understand the typ
Websites are not a secondary means of advertising or information delivery. Risks are increasing as banks increase the functionality of their sites and customers go to their web addresses more than their branches.
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.