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Course description

Experienced bank compliance officers know to study a regulator’s Official Interpretations, sometimes referred to as “Official Staff Commentary” or simply “Commentary,” to find valuable – and legally enforceable – interpretations of regulatory provisions. Oftentimes, the Commentary is more extensive than the regulatory text itself, offering examples to illustrate how the regulator wants a provision interpreted or applied.

FinCEN, however, doesn’t publish Official Interpretations as supplements to its regulations. Instead, it releases the occasional Guidance document, often in the form of a curated list of Frequently Asked Questions or FAQs, in some cases (we suspect) internally developed to anticipate and address parts of a rule that are expected to generate questions from those subject to a regulation, and in other cases to publish a settled and approved response to a question that has actually been asked frequently.

FinCEN’s May 2016 Customer Due Diligence Requirements for Financial Institutions rule clearly raised a lot of questions from bankers. Questions about its impact on CTR filing, relationship to 314(a) inquiries, OFAC checks. Questions about definitions, layers of ownership, ownership by trusts … the list goes on.

In this timely two-hour webinar, Brian Crow and John Burnett will analyze FinCEN’s two-part guidance and its 63 frequently asked questions to help you make certain you understand the implications of the answers for your institution’s implementation of the new regulatory provisions that have to be complied with by May 11, 2018.

Brian and John will cover all 63 of the FAQs to cover these and other issues:

  • The date by which financial institutions have to comply
  • Effect of the rule on future 314(a) searches
  • Use of the "Appendix A" form
  • Legal entity customer: Is it or isn't it?
  • New accounts and established customers
  • Rollovers and renewals: New accounts or not?
  • Unincorporated associations
  • The "exempt lists"-customers and accounts
  • Existing accounts
  • Accounts that aren't deposits or loans
  • The "control prong"
  • When to collect the information
  • "Drilling down"


BSA Officers, compliance officers and others responsible for ensuring compliance with FinCEN's customer due diligence and beneficial ownership rules.


John Burnett and Brian Crow

Course curriculum

  • 1


    • Just the FAQs — FinCEN’s Guidance on Beneficial Ownership and Customer Due Diligence

  • 2


    • Materials

    • Slides

    • Webinar Q & A Document