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Course description

After years of discussion and anticipation, the Beneficial Owner/Customer Due Diligence rule is a reality that every frontline employee of a financial institution will need to deal with. And on April 3, 2018, FinCEN issued its much-anticipated guidance to definitively answer some of the lingering questions about what to do and how to do it. You have trained your staff, you’ve modified your procedures, but this rule is a big game changer, filled with new terminology, new requirements, new customer relations challenges, and only now, with the newest FinCEN issuance do we have all of the puzzle pieces. This program provides strategies and tips for reframing and reinforcing what bank staffers need to know and do under the rule and all FinCEN FAQs.

This is a Train the Trainer program. Whether you're the in-house trainer, BSA officer, or in charge of all compliance matters, this webinar will arm you with key tactics for breaking down the complex concepts for your frontline and ensuring consistent, compliant implementation. Recognizing that this affects various departments within your institution, we will provide guidance about the nuances that come into play and how your approach should differ for the different business units - deposits, loans, safe deposit rentals. You'll get charts and quick reference guides to help your staffers take a consistent, methodical approach to compliance.

Perhaps you have already conducted bank-wide training on the new rule – but you didn’t know what you couldn’t know, the answers only FinCEN could give, and those were just released April 3, 2018, 23 months into your two year implementation timeline! Our experience shows us that employees absorb the information in layers, piece by piece. We’ll help you deliver all the pieces. Rather than simply hitting “replay” to tell them what you already told them, our program will equip you with a fresh set of explanations, illustrations, examples, even scripts, to get you out of the box.

This program will provide training tips for every aspect of the rule, including:

  • Important definitions
  • Why the rule was adopted
  • Consequences of noncompliance
  • When the rule is applicable
  • To which customers the rule applies
  • How to talk to the customer about the new requirements
  • Questions customers are likely to ask - and the answers to them
  • Understanding the two prongs: ownership and control
  • What information must be obtained
  • Explaining the "direct or indirect" test for beneficial ownership
  • All about the certification
  • The bank's responsibility vs. the responsibility of the person opening the account
  • How this is different from CIP; how it is similar
  • Verification of identity
  • When you can't proceed
  • The effect of not having an "existing customer" exception
  • If your bank has set stricter requirements than the rule (such as a lower threshold for beneficial ownership)
  • Common misconceptions to avoid
  • What happens when an automatically renewable CD renews
  • What’s the impact of the rule on loan renewals?
  • Close-in-time new accounts and your responsibilities
  • What you need to know about risk-related triggers
  • When re-certification of beneficial ownership is required

<b>Who should attend: </b>
This program is designed for in-house trainers, BSA officers, compliance officers who are responsible for doing training and/or ensuring compliance with FinCEN's Beneficial Owner/Customer Due Diligence rule.


Mary Beth Guard and Brian Crow

Course curriculum

  • 1


    • Last Minute Training Tips for BO and CDD

  • 2


    • Slides - pdf

    • Slides - ppt

    • Webinar Q & A Document