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The below article is part 3 of a 4 part series.
Currently, federal regulators expect you to have and maintain an adequate customer due diligence program that is appropriate for your institution’s size and complexity and in line with your overall risk assessment and the risk assessment for any group of individual accounts or individual customers or members. In September 2014, the Financial Crimes Enforcement Network (FinCEN) proposed to codify that expectation with a revision to 31 CFR 1020.210, which would add one more basic requirement for your anti-money laundering program. In addition to requiring that you have internal controls for compliance with the law, an independent test, a BSA officer, and a training program, the proposal states that you will also be required to have:
Appropriate risk-based procedures for conducting ongoing customer due diligence, to include, but not be limited to:
(i) Understanding the nature and purpose of customer relationships for the purpose of developing a customer risk profile; and
(ii) Conducting ongoing monitoring to maintain and update customer information and to identify and report suspicious transactions.
The proposal also makes changes to the requirements for your customer identification program (CIP) program that would include identification of beneficial owners for new accounts. This rule may be final sometime in 2016.
Read on, download the full PDF, Emerging State Anti-Money Laundering Issues [As modeled by the state of New York]
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If you missed any of the series check out the article(s) below:
Emerging State Anti-Money Laundering Issues: Introduction
Emerging State Anti-Money Laundering Issues: Summary of Proposed Rule