CDD And The 5th Pillar

Webinar: ID# 1023831
Recorded CD or On-Demand
About This Course:
On May 11th, 2016 FinCEN's codified previously implied, or implicit, guidance with explicit Customer Due Diligence (CDD) requirements regarding understanding the nature and purpose of legal entity accounts to develop an initial risk profile and ongoing monitoring.

Most of the headlines have addressed the new Beneficial Ownership rule but the new 5th Pillar is already being addressed in recent Consent Decrees. Don't be the next bank to make news regarding deficiencies in your bank's CDD process.

This two-hour program identifies which guidance has now become a regulatory requirement and needs to be addressed immediately. We will address the CDD guidance in the Core Examination section of the Interagency BSA/AML Examination Manual as well as various section of the Expanded Examination sections such as Cash Intensive Businesses, Professional Service Providers, Nongovernmental Organizations, etc.

The program will include a review of the major regulatory findings regarding the customer risk profile initial process along with the need for periodic monitoring. Additionally, we will discuss the corrective actions set forth in the recent BSA written consent actions and keep your bank off the regulatory radar.

Covered Topics:

  • Higher risk customer types that need frequency monitoring in comparison to lower risk customer types that need infrequent monitoring
  • BSA policy and program requirements and changes
  • Regulatory requirements
  • Types of accounts to include in CDD monitoring
  • Board and Senior Management expectations and responsibilities
  • Baseline determination of "normal" vs "suspicious" activity
  • Development of an initial customer risk profile
  • Threshold for updating a customer profile
  • Connecting the dotted line between unusual CDD activity and the filing of a SAR
  • CDD and its impact upon the bank's annual BSA Risk Assessment
  • How to avoid examination and audit findings
  • Record Retention
  • Transactional internal testing
Participants receive a detailed manual that serves as a valuable resource long after the conclusion of the program which will serve as a vital resource in enhancing your bank's written BSA Program.

Who Should Attend

The program is designed for BSA Officers, Compliance Officers, Branch Administration, Deposit Operations, Senior Management, Auditors, and those responsible for the development, implementation, maintenance and oversight of a bank’s BSA program.

The Presenter

Don Blaine is a Senior Training Consultant for Compliance Resource, LLC. Don has over 30 years of experience in regulatory compliance for the banking industry with banks ranging in size from community banks to money center banks. He provides training on Bank Secrecy Act/Anti-Money Laundering and deposit compliance. His prior roles have included: Chief Compliance Officer, Senior Compliance Regulatory Examiner, Compliance Audit Manager, and business unit compliance manager.

Don has taught at the ABA’s National Compliance School and has served as an instructor at programs offered by state banking associations. Prior to joining Compliance Resource, LLC, Don served as a consultant to numerous banks. He has attained Certified Regulatory Compliance Manager (CRCM) and Certified Risk Professional (CRP) certifications.
CDD And The 5th Pillar
or via CD or On-Demand
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