FinCEN's Beneficial Ownership Rule: New Due Diligence Requirements for Customer Ownership and Control
Recording of a 90-minute premium CLE webinar with Q&A
This CLE course will examine FinCEN’s new regulation, “Customer Due Diligence Requirements for Financial Institutions,” known as the “CDD Rule,” “Beneficial Ownership Rule,” or “Beneficial Owner Rule” (Rule) and how it will impact anti-money laundering (AML) procedures of banks and other covered financial institutions (CFIs) that must comply with the Bank Secrecy Act. The topics discussed by the webinar panel will include recent FAQ guidance on the Rule provided by FinCEN, and the added complexities that arise for parties making and receiving money transfers.
- Elements of the Rule
- Individual(s) with 25%+ direct or indirect ownership
- 1 individual with management control
- Key aspects of the broader CDD requirements
- Nuances as outlined in FAQs
- Process and method of verification
- Required information
- Existing customers who open new accounts, multiple accounts
- Account renewals and rollovers—treated as new accounts
- Record retention
- Implementation & compliance challenges
- Incorporating the Rule’s provisions into a robust AML program
The panel will review these and other critical issues:
- How does the Rule alter due diligence requirements for bank customers that are legal entities?
- What are the elements of a robust, compliant AML program, and how should existing procedures be modified to incorporate the Rule?
- What are the additional insights in FinCEN’s recent release of FAQs regarding the Rule?
- The Rule provides a compliance floor; what will regulators see as the ceiling? Is there one?
Elizabeth A. Khalil, CIPM, CIPP/US, CIPP/EU
Ms. Khalil focuses her practice on all aspects of regulatory compliance and risk management for the financial services... | Read More
Ms. Khalil focuses her practice on all aspects of regulatory compliance and risk management for the financial services industry, including consumer protection, privacy/data security, third-party relationships, Bank Secrecy Act/anti-money-laundering (BSA/AML), and the full “alphabet soup” of federal banking laws and regulations. She advises clients on improving their overall compliance management systems and compliance programs, including privacy/data security programs, BSA/AML programs, and third-party/vendor management programs. Ms. Khalil also regularly drafts and revises individual policies and procedures within a program. She also provides counsel on permissible bank and bank holding company activities and assistance with corporate applications, including regulatory due diligence in connection with mergers and acquisitions.Close
Ms. Welch is a director in the firm’s Global Investigations and Compliance Practice. She works with financial... | Read More
Ms. Welch is a director in the firm’s Global Investigations and Compliance Practice. She works with financial services clients to address their anti-money laundering, counter-terrorism finance, sanctions, and bank regulatory compliance challenges. Prior to joining Navigant in June 2016, Ms. Welch held compliance roles at Morgan Stanley, RBC Capital Markets, HSBC, and JPMorgan.Close