On May 11, 2016, the Customer Due Diligence (CDD) Final Rule was published in the Federal Register and banks were given two years to prepare. Can you believe that a year has already passed? One down, one to go! If you haven’t started to develop an action plan and/or inform your Senior Management and Board of Directors, it’s time to move it to the top of your “to-do” list!
It’s important to note that it’s extremely unlikely there will be any sort of transition or leniency period like we had with TRID. The seriousness of money laundering and terrorist financing crimes, as well as national security, will prevent any reduction of regulation in this area. You do not want to be found “non-compliant” as of the mandatory compliance date of May 11, 2018!
In the next year, you will need to review/revise your current policies, procedures, processes, forms, core software systems, Anti-Money Laundering (AML) software (if applicable), TRAIN your employees, educate your customers, test your processes and on and on. There’s a lot to do but don’t worry, we’ve got you covered!
- If you need help getting your action plan in place, we will be offering a FREE Forum on May 3, 2017, to get you on the right track.
- If you need more details on the nuts and bolts of the CDD & BO requirements, we will be offering a webinar, “Customer Due Diligence Programs & Beneficial Owners”, on July 12, 2017.