CDD and the 5th Pillar Webinar
The program will include a review of the major regulatory findings regarding the customer risk profile initial process along with the need for periodic monitoring. Additionally, we will discuss the corrective actions set forth in the recent BSA written consent actions and keep your bank off the regulatory radar.
Webinar Description and Audience
On May 11th, 2016 FinCEN’s codified previously implied, or implicit, guidance with explicit Customer Due Diligence (CDD) requirements regarding understanding the nature and purpose of legal entity accounts to develop an initial risk profile and ongoing monitoring. Most of the headlines have addressed the new Beneficial Ownership rule but the new 5th Pillar is already being addressed in recent Consent Decrees. Don’t be the next bank to make news regarding deficiencies in your bank’s CDD process. The regulators are not reinventing the wheel but enforcing guidance that has been in place for years.
This two-hour program identifies which guidance has now become a regulatory requirement and needs to be addressed immediately. We will address the CDD guidance in the Core Examination section of the Interagency BSA/AML Examination Manual as well as various section of the Expanded Examination sections such as Cash Intensive Businesses, Professional Service Providers, Nongovernmental Organizations, etc.
The program will include a review of the major regulatory findings regarding the customer risk profile initial process along with the need for periodic monitoring. Additionally, we will discuss the corrective actions set forth in the recent BSA written consent actions and keep your bank off the regulatory radar. This program is intended for a wide range of bank personnel who are involved in the first, second or third line of defense for BSA.
FinCEN, and banking regulatory agencies, believe that requiring banks to perform effective CDD on legal entity customers will assist the bank in better understanding who the actual customer is and what type of transaction(s) they normally conduct to set a baseline for the identification and reporting of suspicious activity. The purpose of the new rule is to allow banks to assist the government, and law enforcement, in combating numerous types of illicit financial activities including tax evasion, terrorist financing, money laundering and sanction violations among others.
Written, Board-approved BSA/AML Programs have long addressed the four pillars but now need to either revise portions of the Internal Controls section into a new fifth pillar or augment the written policies with new procedures that include:
•Understanding the nature and purpose of customer relationships for developing a customer risk profile
•Conducting ongoing monitoring to identify and report suspicious transactions and, on a risk basis, to maintain and update customer information
Participants receive a detailed manual that serves as a valuable resource long after the conclusion of the program which will serve as a vital resource in enhancing your bank’s written BSA Program.
•Higher risk customer types that need frequency monitoring in comparison to lower risk customer types that need infrequent monitoring
•BSA policy and program requirements and changes
•Types of accounts to include in CDD monitoring
•Board and Senior Management expectations and responsibilities
•Baseline determination of “normal” vs “suspicious” activity
•Development of an initial customer risk profile
•Threshold for updating a customer profile
•Connecting the dotted line between unusual CDD activity and the filing of a SAR
•CDD and its impact upon the bank’s annual BSA Risk Assessment
•How to avoid examination and audit findings
•Transactional internal testing
Who Should Attend?
The program is designed for BSA Officers, Compliance Officers, Branch Administration, Deposit Operations, Senior Management, Auditors, and those responsible for the development, implementation, maintenance and oversight of a bank’s BSA program.
Webinar Viewing Options
INCLUDES 7 DAYS OF UNLIMITED ONDEMAND PLAYBACK! With this option, you will participate in the webinar (via the internet) as it is being presented. You will login to the webinar on your PC to view the PowerPoint presentation, and you have the option of using your PC speakers or a telephone for the audio. You can type and send your questions to the instructor. Many companies are now running their PC through an LCD projector allowing many employees to participate at the same time. And don’t worry if you miss the webinar, you can still view it for up to seven days after it takes place!
SIX MONTH ONDEMAND VIDEO:
With this option, you will receive an e-mail that contains a link to the PowerPoint slides (to download, print, and copy) as well as a link to the media player where you will view and hear the entire webinar just as it was delivered, featuring the full-color PowerPoint presentation with audio. You can pause, fast-forward and rewind as needed, which makes it a very effective training tool. The OnDemand Video will be available to you (and anyone else in the company) for six months and can be accessed 24/7 as many times as you wish. Delivered via e-mail the day after the webinar takes place.
If you do not have internet access or want to make the webinar part of your training library, the CD-ROM Recording is a great option for viewing a webinar. You can pause, fast-forward and rewind as needed, which makes it an effective training tool. With this option, you will receive a download of the PowerPoint slides and a CD-ROM Recording (featuring PowerPoint presentation with audio) of the webinar via regular mail. Mailed 7 to 10 days after the webinar takes place.
Webinars can be scheduled and offered exclusively for your company. They can even be customized to best fit your needs. To find out more, please complete the in-house request form found in the Schedule and Registration Information section below.
Continuing Education (CE) Credits
This webinar is recommended for 2.5 CE Credit Hours. Each attendee will receive a Certificate of Attendance for self-reporting of CE Credits.