As the Financial Crimes Enforcement Network’s customer due diligence rule — which includes a new requirement to verify “beneficial owners” of legal entity customers — takes effect today, the federal banking agencies issued new exam procedures for the rule. One set of exam procedures on customer due diligence replaces those in the current Bank Secrecy Act/anti-money laundering exam manual, and another set provides exam procedures for the new beneficial ownership requirements.
The American Bankers Association is reminding member bankers that they can access a host of resources online to facilitate compliance with the rule. The resources include a staff analysis of FinCEN’s latest set of FAQs on the rule; a set of FAQs published by ABA that supplement the guidance provide by FinCEN; a sample letter, desk notice, certification form and talking points; and links to ABA training on the rule.
