FinCEN's CDD rule FAQs covered in new BSA Blast
NAFCU's quarterly BSA Blast e-newsletter, released to members yesterday, provides detailed explanations to some of the questions NAFCU has received related to the Financial Crimes Enforcement Network's (FinCEN) customer due diligence (CDD) rule, which has a mandatory compliance deadline of May 11.
The article, written by NAFCU Regulatory Compliance Counsel Stephanie Lyon, includes detailed responses to five questions:
- whether the CDD rule requires credit unions to collect signatures from legal entity members when they open an account;
- if a credit union should identify the owners of a business or the business itself when documenting the beneficial owner, if the business owns 25 percent of a legal entity;
- whether the trustor or the trustee of a trust that owns a legal entity should be identified in order to meet the beneficial ownership requirement;
- what is a qualifying event that would require credit unions to gather beneficial owner information on existing members; and
- if credit unions need to revise compliance signage for the USA Patriot Act.
Lyon also details other requirements of the CDD rule and provides additional resources – including FinCEN's first and second sets of interpretive guidance – to help credit unions meet the compliance deadline.
A separate article in the e-newsletter, by NAFCU Regulatory Paralegal Shari Pogach, details two recent enforcement actions taken by FinCEN and federal banking regulators. The actions included forfeitures and penalties totaling the highest ever annual total for federal authorities for Bank Secrecy Act and anti-money laundering (BSA/AML) violations in any prior years.
This issue of the BSA Blast also includes a forum with questions and answers about filing a suspicious activity report (SAR) when a validated identity theft is involved and whether credit unions need to keep copies of identification for new members opening an account.
A BSA quiz is also included in this quarter's e-newsletter, which focuses on the CDD rule.
Add to Calendar 2019-06-06 14:00:00 2019-06-06 14:00:00 BSA: The SAR Narrative Process The Suspicious Activity Report (SAR) Narrative is a crucial part of a credit union’s Bank Secrecy Act (BSA) reporting process. The narrative should provide law enforcement with key information surrounding any suspicious activity that may be occurring at your institution. In this webinar, you will learn how to write the type of narrative to entice law enforcement to move your report to the must read pile! We’ll also discuss the SAR process and provide best practices for drafting a strong narrative. Key Takeaways: Discuss how to monitor suspicious activity Review SAR Drafting Understand how to defend your narrative Learn how to defend your decision(s) not to file Purchase Now$295 Members | $395 Nonmembers (Additional $50 for CD) One registration gives your entire credit union access to the on-demand recording until June 6, 2020.Already registered? Go to the Online Training Center to view live. Who Should Attend? NAFCU Certified Bank Secrecy Officers (NCBSOs) NAFCU Certified Compliance Officers (NCCOs) NAFCU Certified Risk Managers (NCRMs) BSA Staff Compliance Staff Risk Staff Credit Union Staff Attorneys Open to all credit unions, regardless of membership or charter type! Education Credits NCCO credit information is below; recommended 1.5 CPE credits. NCRM credit information is below; recommended 1.5 CPE credits. NCBSO credit information is below; recommended 1.5 CPE credits. CPA credit information is below; recommended 1.5 CPE credits. CPA Certification Credit Information Reviewer: Josie Collins, Associate Director of Education, NAFCU Learning Objectives: Discuss how to monitor suspicious activity. Review SAR Drafting. Understand how to defend your narrative. Learn how to defend your decision(s) not to file. Program Level: Basic Prerequisites Needed: None Advance Preparation Needed: None Delivery Method: Group Internet-Based Recommended CPE Credits: 1.5 credits Recommended Field of Study: Regulatory Ethics - Technical National Association of Federal Credit Unions (NAFCU) is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. Learn more. About Our Webinars Our webinars are streamed live from NAFCU headquarters near Washington, D.C. Your audio/video feed of the presenters includes presentation slides and downloadable handouts. You can easily submit your questions to the presenters at any time during the live broadcast, with no dialing over the phone! The audio and video stream directly through your computer. Web NAFCU email@example.com America/New_York public
Credits: CPE, NCCO, NCRM, NCBSO
Get daily updates.
Subscribe to NAFCU today.