New Customer Due Diligence Beneficial Owner Rule

Why Should You Attend:

FinCEN issued the Customer Due Diligence (CDD) Rule last year to amend existing BSA regulations in order to clarify and strengthen customer due diligence requirements for certain financial institutions. Along with outlining explicit customer due diligence requirements, the rule also enacts a new requirement for these financial institutions to identify and verify the identity of beneficial owners of legal entity customers, subject to certain exclusions and exemptions.

In this breakout session, the webinar instructor will review the CDD Rule and the new requirements issued by FINCEN, along with sharing information and procedures for the beneficial ownership rule.

Areas Covered in the Webinar:

• Background on the new Customer Due Diligence Beneficial Owner rule
• Beginning the project - how to start, where to start
• Creating a project plan
• Who are involved in the CDD B.O project
• Creating flow charts to make out current process and future process
• Examples of what decisions points are needed
• How to train and who to train
• How to implement the project
• 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
• Regulatory requirements
• 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
• Record retention
• Transactional internal testing

Who Will Benefit:

• BSA Officers
• BSA Staff
• CIP and Deposit Operations
• Anti-Money Laundering Officers
• Internal Auditors
• Financial Officers
• Front Line Staff
• Risk Officers
• Operational Managers
• Branch Personnel
• Training
• Compliance
• Staff with roles and responsibilities in BSA / AML management and oversight
• Anyone who opens legal entity accounts

Joe Soniat
Bank Secrecy Act Officer, Union Bank and Trust

Robert J. Soniat (Joe) is the BSA officer for Union Bankshares Corporation, located in Richmond, Virginia. He also worked as a finance officer for the United States Government from 2002 – 2004. He holds a Bachelor’s of Science in Accounting from Virginia Commonwealth University as well as minors in criminal justice and international relations.

Mr. Soniat is a Certified Anti Money Laundering Specialist (CAMS) with an advance certification in Financial Crimes Investigations (FCI). He is also a Certified Fraud Examiner as well as a Certified Anti Money Laundering and Fraud Specialist (CAFP). He is on the BSA Coalition Advisory Board as well as the ACAMS Virginia Chapter Board.

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