BSA Compliance Series: FinCEN’s CDD Rules & BSA Compliance: Why Preparing Now for the Fifth Pillar is Critical

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This webinar will address two issues regarding the fifth pillar of the new customer due diligence rules. First will be an overview of changes that mandate additional procedures to “understand the nature and purpose” of the legal entity relationship to develop a “reasonable” risk profile. The second will be how to conduct ongoing monitoring to identify and report suspicious transactions and, on a risk basis, maintain and update accountholder information. FinCEN provided ample lead time to navigate these substantial changes to policies, procedures, forms, and effective monitoring processes. Regulators will expect financial institutions to have an implementation plan well in advance of the May 11, 2018, effective date to meet these challenges.


  • How to comply with the four core elements of the CDD rules
    • Customer identification and verification
    • Beneficial ownership identification and verification of a “legal entity”
    • Understand the nature and purpose of customer relationships to develop a customer risk profile
    • Ongoing monitoring for suspicious transactions, and, on a risk basis, maintaining and updating customer information
  • Documenting the two-prong test for beneficial ownership and control of a legal entity
  • What does the frontline and lending staff need to know?
  • How will BSA staff, operations, and the audit function support the new rules?
  • What new internal controls will be required?
  • Tips to identify suspicious activity, beginning with establishing an activity baseline at account opening
  • Four unique sources of risk for legal entity accounts, including terrorist financing, money laundering, business identity theft or fraud, and business account takeover
  • Events that may trigger an update to the risk profile for both loan and deposit accounts

ABOUT THE PRESENTER – Susan Costonis, Compliance Consulting and Training for FIs

Susan Costonis is a compliance consultant and trainer who began her career in 1978. She specializes in compliance management along with deposit and lending regulatory training. Susan has successfully managed compliance programs and exams for institutions that ranged from a community bank to large multi-state bank holding companies. She has been a compliance officer for institutions supervised by the OCC, FDIC, and Federal Reserve. Susan has been a Certified Regulatory Compliance Manager since 1998, completed the ABA Graduate Compliance School, and graduated from the University of Akron and the Graduate Banking School of the University of Colorado. She regularly presents to financial institution audiences in several states and “translates” complex regulations into simple concepts by using humor and real life examples.

Originally recorded on February 8, 2017.

Recorded webinar available until December 31, 2017.

Free Digital Copy included with purchase to download and view beyond link expiration date.

Price includes sales tax.