The impending Final CDD Rule breaks out parts of the BSA into the new 5th Pillar. Many of the requirements of the Final CDD Rule are already being practiced in theory by financial institutions, while other financial institutions are grappling with implementing new procedures to meet the new requirements. Pushback for more “BSA stuff” from the frontline is a common hurdle for BSA officers. However, much of the information that is already being collected as part of the Customer Identification Program (CIP) and Know Your Client (KYC) process can be leveraged to meet the new requirements, but additional process will still need to be implemented and reevaluated to ensure ongoing compliance.
This webinar will examine the information or documentation already being collected and its use to meet the 5th-Pillar standards. An example of a new accounts workflow review will be illustrated to show at what stage of the new accounts process certain CDD information is collected and can be leveraged. A sample review of policy and procedures will be shown from both the frontline/operational and the BSA perspective to ensure the new CDD process is implemented and sustained over time. This webinar will cover:
- Core elements of the Final CDD Rule
- Operational and BSA policy and procedures, including workflows
- New Accounts documentation review, including convoluted business structures
- Triggering events/ event-based account reviews
- Certifications of Beneficial Ownership (CBO)