The FinCEN CDD Rule brought focus to the issues surrounding Customer Due Diligence, which includes the broader concept of CIP. CDD has significant implications for understanding of beneficial ownership and PEPs. However, financial institutions who offer correspondent banking, especially foreign correspondent banking, challenges them to “dig deep” into their correspondent accounts and assess their risk to the institution. Although an implementation challenge, CDD enables FIs to have an even more comprehensive understanding of their customers. With this in mind, we will explore the implementation challenges with a focus on higher risk scenarios and the feedback FIs have received thus far with the changes they’ve seen to their programs.
Areas Covered in the Webinar:
- History of the rule
- Purpose of the rule
- Is the Rule providing added value and benefits?
- Who is a owner?
- CDD/EDD/On-Going Risk Based Monitoring
- Correspondent Banking
Who Will Benefit:
- Banking compliance Personnel
- Credit Union compliance Personnel
- Financial institution compliance Personnel
- Branch Management Staff
- Training Department/Program Professionals
- District Bank/Credit Union/Financial Institution Managers
- Teller Supervisors
- Compliance Managers
- Compliance Analyst/Investigators
William Schlameuss has over 20 years’ experience in regulatory compliance, including BSA/AML/OFAC. He has worked with a wide range of US branches of major foreign banking organizations from all continents, both as chief compliance officer and compliance consultant. He has a prior background in IT as manager and implementer of core banking and payment systems, as well as compliance-related systems.
Mr. Schlameuss has extensive experience with State and Federal Banking regulators in examination preparation, assistance and response, including assistance in the remediation of written agreements for clients.
As a project manager Mr. Schlameuss has led BSA/AML audits, BSA/OFAC Model Validations, remediation efforts of BSA audit issues, and BSA/OFAC look-backs for international banks, both self-imposed and directed by regulatory authorities. Model Validations included Prime, FCRM, Patriot Officer, Actimize, and eGIFTS.
He has conducted the Annual 3130 Supervisory Reviews for Broker-Dealers of the US branches of major FBOs. Mr. Schlameuss is also a member of the Association of International Bank Auditors and the International Bank Regulatory Compliance Committee.
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