August 04, 2020

FinCEN releases additional customer due diligence FAQs

BSAThe Financial Crimes Enforcement Network (FinCEN) Monday issued three frequently asked questions on customer due diligence (CDD) requirements for covered financial institutions. The FAQs, released in collaboration with the federal functional regulators, cover issues related to risk-based procedures, the customer's risk profile, and on-going monitoring.

The FAQs, which also address the requirements and certain flexibilities available under the CDD rule, are in addition to those previously issued by FinCEN in July 2016 and April 2018.

NAFCU has continuously advocated for Bank Secrecy Act (BSA)/anti-money laundering (AML) reforms, which is one of the association's advocacy priorities for 2020. Lawmakers in the House last year passed NAFCU-supported legislation to reduce the burden of suspicious activity report (SAR) and currency transaction report (CTR) filings, and would better equip financial institutions for compliance with the CDD rule.

For additional information regarding customer due diligence requirements, credit unions are encouraged to visit FinCEN's dedicated CDD webpage. Those with questions or comments regarding the guidance may contact FinCEN's Regulatory Support Section.

Additionally, NAFCU has a webinar available on-demand addressing the legal requirements, implementation challenges, and supervisory expectations for the CDD rule. The association also has a host of other resources available.