The May 11, 2018, mandatory compliance date is fast approaching for the “strengthening’ Customer Due Diligence and Deb11the new Beneficial Owner rules. Will you be ready? Where are you at with your action plan? Have you thought of everything? Will you have time to test your process before implementation? Are you keeping Management and the Board apprised of your progress? Have you trained the Board on the major requirements of the new rule? Don’t forget to do this BEFORE you submit the updated BSA/AML/OFAC Policy and Customer Due Diligence Program for their approval. The Board needs to be informed and knowledgeable of the regulatory requirements in order to approve Policy and to provide direction for the BSA/AML Program; after all, they are ultimately responsible for the bank’s BSA/AML compliance! To help you out, we’ve put together a list of checkpoints (see below) to keep you on track and to keep your Management and Board informed.


Also, if you’re looking for additional training on the Customer Due Diligence and the new Beneficial Owner rules, we’ve got you covered. On February 7, 2018, we will be offering a 2-hour webinar on Customer Due Diligence Programs & Beneficial Owners and then on April 4, 2018, we will be offering a 1-hour webinar on Customer Due Diligence & Beneficial Owners for Commercial Lenders.


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Deb Irving

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