FinCEN's CDD Rule - The New Fifth Prong of the AML

FinCEN's Customer Due Diligence (CDD) rule expanded Know Your Customer into a fifth pillar of AML under the BSA. It reaches beyond the customer legal entity to the entity's beneficial owners and controlling persons, and beyond account opening to ongoing updating and monitoring against a baseline of normal activity for the customer type.

This 60-minute FinCEN CDD rule webinar starts with the existing four pillars of AML, then explains the fifth: what triggered the expansion, its purposes according to FinCEN, the three covered entity types and the exclusions. You'll review the requirements for risk profiles, updating customer information, establishing baseline transactions and transaction monitoring. Full compliance is required for accounts opened on or after May 11, 2018.

• Describe the four existing pillars of AML and the fifth CDD pillar
• Explain why FinCEN expanded the requirements and their purposes
• Identify customer legal entities, beneficial owners and controlling persons
• Apply the exclusions in the rule
• Build customer risk profiles and keep them updated
• Monitor transactions against baseline normal activity

• The existing four pillars of AML under the BSA
• Overview of the fifth pillar
• Triggers behind the expanded regulations
• Purposes of the rule according to FinCEN
• Three covered entity types: customer legal entity, beneficial owners and controlling persons
• Exclusions
• Requirements: risk profiles, updating, baseline normal transactions and transaction monitoring

CDD goes well beyond traditional KYC, and before it became a requirement few banks met these standards. Understanding the rule helps your institution identify beneficial owners correctly and monitor customer activity on an ongoing basis.

This session suits commercial, small business, private and international banking staff, new customer processing staff and supervisors, and fraud, compliance and AML professionals at banks, brokers and other depository institutions.

Commercial banking, Small Business Banking, Private Banking, and International Banking.
New customer processing staff and supervisors
Banks, brokers, other depository institutions

• Fraud
• Compliance and AML
• VP
• Manager
• Director
• Supervisor

Jim George is an independent consultant to banks focusing on issues of fraud. He brings over 25 years as a consultant to major banks in Associate Partner and Principal roles at PriceWaterhouse-Coopers Consulting, IBM Consulting in Bank Risk and Compliance and Andersen Consulting (now Accenture). He has also been SVP Operations for a Fortis-US division providing outsourcing services to the banking industry. 

Jim's work has included projects in fraud investigation, fraud prevention, identity issues, compliance and AML (anti-money laundering). His background includes work in bank operations and payments strategy, reengineering, systems and quality improvement.