ICB Credit: 2.5 CRCM

U.S. financial institutions have been given two years, until May 11, 2018, to develop individual programs for identifying a legal entity’s “beneficial owners” at account inception. Examiners and auditors cannot mandate early compliance (although some attempts have been noted in the BankersOnline forums), but they can critique a bank’s understanding of the new regulation or the adequacy of its steps toward compliance at the time of their review.

The rule adds a new “fifth pillar” to your AML program mandating that your institution establish and update customer information to assure that your bank knows what is “normal” vs. “suspicious” activity for higher risk customers. Also, your institution is required to identify the “beneficial owners” and a control person for each of its legal entity customers, regardless of perceived risk, whenever they open a new account and you are required to verify their identity. That is true whether it is a loan, deposit, or trust relationship.

This fast-paced two hour session allows attendees to familiarize themselves with the requirements of the new regulation and develop an implementation plan that will require both board involvement in revising policies and operational involvement in revising account opening procedures.

Topics addressed in the webinar include:

• Legal entities 101
• What do you actually need to read and digest?
• Developing a Due Diligence Policy (sample provided)
• The “ownership” and “control” prongs of the rule
• Appendix A (the form that can be used by the entity to provide information)
• Revising Appendix A (samples provided)
• Trashing Appendix A
• How do we verify identity?
• Supplementing your CIP with a “BOIP”
• Handling identification misfires
• Excluded entities
• Record retention
• What do we do with the information? (Hint: Putting it in a file until an examiner asks for it is not the right answer.)

Who Should Attend: The program is focused on new requirements added to the Bank Secrecy Act regulations. Those who would naturally attend are the BSA Officers and Auditors. However, the most direct impact of this new regulation is going to be on those who design and manage the “new accounts” process which will be tasked with obtaining more information from legal entity customers. They need to be in the room and be kept informed when these decisions are made.

This is an improved version of a BOL webinar presented in June, 2016. Repeat attendance is not encouraged unless you are using it to train additional staff members.