FinCENs CDD Rule

On September 14, 2020, the U.S. Department of the Treasury's Financial Crimes Enforcement Network ("FinCEN") issued a final rule ("Rule") requiring the minimum standards for anti-money laundering programs for certain institutions lacking a Federal functional regulator.

The Rule applies to banks that lack a Federal functional regulator, including, but not limited to, private banks, privately insured credit unions, and certain trust companies. The Rule also extends customer identification program and beneficial ownership requirements to those institutions.

​FinCEN noted that it expected that banks lacking a Federal functional regulator "will be able to leverage existing policies, procedures, and internal controls required by other statutory and regulatory requirements to fulfill the obligations set out in the final rule." Banks lacking a Federal functional regulator have 180 days from the day of the Rule's publication in the Federal Register to be in compliance. The rule was published on September 15, 2020, noting a deadline of compliance of March 15, 2021.

This event will expand your knowledge of these new compliance requirements. It will position your institution to have in place the compliance program elements for the Fifth Prong of the AML Program.

This CPE event will cover the following learning objectives:

• Learn about the FinCIN CDD requirements,

• See how to be fully compliant with the requirements,

• Understand all the requirements of a compliance program for a retail bank concerning CDD.

The major agenda items within this intense CPE training event are answering:

• The original 4 prongs of AML (anti-money laundering) per the BSA (Bank Secrecy Act)

• Overview of the 5th prong

• Triggers that caused this expansion of regulations

• Purposes of the regulation, per FinCEN

• Three covered entity types:

• Customer legal entity

• Beneficial owners

• Controlling persons

• Exclusions

• CDD Requirements

• Risk profiles

• Updating

• Baseline/normal transactions

• Transaction monitoring

• The difficulty in implementation.

Program Level of Understanding: Basic
Prerequisites: None
Advance Preparation: None
Delivery Format: Group Internet Based
NASBA Field(s) of Study: Auditing
CPE Credits: 2, based on 50 minutes of instruction per hour

This CPE training event overviews into the Financial Crimes Enforcement Network's (FinCEN) Customer Due Diligence (CDD) Rule, which mandates covered financial institutions to implement robust processes for identifying and verifying the identity of beneficial owners of legal entity customers.

This CDD Rule aims to enhance transparency in financial transactions, mitigate money laundering risks, and combat illicit financial activities. The event provides comprehensive insights into the requirements, compliance obligations, and best practices related to the CDD Rule, equipping participants with a deep understanding of how to effectively implement and adhere to these crucial regulatory standards.