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Product ID: 406929EAU
 
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Advanced Due Diligence: A Cornerstone of any BSA/AML Program

OnDemand Webinar (88 minutes)

Gain valuable insight to advanced due diligence and the requirements of risk-based customer due diligence.The Bank Secrecy Act (BSA), as amended by the USA Patriot Act (Patriot Act), requires financial institutions, including banks, credit unions, broker-dealers, and money services businesses (MSBs), to develop and implement anti-money laundering (AML) compliance programs. FinCEN has recently issued final rules under the BSA to clarify the four core elements of customer due diligence (CDD) and to strengthen requirements, including by introducing new rules for identifying and verifying the identities of beneficial owners of legal entity customers. This topic will provide important updates on the new legal requirements as well as an in-depth look at the elements of a sound CDD program from initial due diligence to ongoing monitoring to escalating and reporting. This topic is critically important for ensuring that your customers are properly risk assessed and for avoiding regulatory criticism of your compliance program.

Authors

Stephanie R. Hager, Stevens & Lee Frank A. Mayer III, Stevens & Lee Steven Szaroleta, Freeh Group International Solutions, LLC

Agenda

Insights Into Requirements of Risk-Based Customer Due Diligence (CDD)

• Does CDD Fit Into the BSA Framework?

• Requirements for Banks vs. Nonbank Financial Institutions

General Due Diligence

• FinCEN's CDD Rule - the CDD Rule Has Four Core Requirements - Establish and Maintain Written Policies and Procedures That Are Reasonably Designed to:

• Special Procedures Requirements When Institution Cannot Perform Either General or Enhanced Due Diligence

• Correspondent Accounts Procedures

• Private Banking Accounts Procedures

How to Escalate Processes When High-Risk Members Require Enhanced Due Diligence

• Enhanced Due Diligence

How to Conduct Ongoing Due Diligence and Constantly Reassess Risk

• Tips for Developing Customer Risk Profiles

• FinCEN CDD Rule Questions and Answers and Guidance

• SARs