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7 Ways to Be Prepared for May 11th

May 3, 2018
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may 11th


Are you ready for the May 11th deadline?

The new Beneficial Ownership regulations and Customer Due Diligence rule deadline is just a few days away. This is considered the most significant change to BSA since the US Patriot Act and non-compliance will result in severe penalties. 

To confirm, FinCEN Director Kenneth Blanco stated at the West Coast AML Forum on Wednesday that there will not be an extension of the May 11th deadline. We’ve had two years to prepare so we should be ready.

In case you’re not quite there yet, here are seven ways to make sure your financial institution is ready come May 11th

  • Check in on Your Board of Directors – Ensure your Board has a high level of understanding of the new CDD rule. Your customers may be going to them with questions or concerns. Need a place to start? Read our white paper on the BO FAQs and CDD key takeaways on the new ruling.
  • Make Sure Your Front Line is Ready – We know the back office has spent over two years training up on the new rules and regulations, but what about your front line? Make sure they are trained and ready to capture this information in the most customer-friendly, non-intrusive way possible.
  • Get Other Departments on Board – Check with your commercial lending, trust and private banking departments to confirm that they understand the importance of these new regulations and how they apply to them. Make sure they are fully onboard with these new requirements.
  • Update Your BSA Policy – Double check that your BSA policy is enhanced to include compliance with the new rule. Specifically, add the Beneficial Ownership language in your CIP section.
  • Double Check Your Procedures – Do your procedures include the new rule? Do they address the certification and retention of the Beneficial Ownership required form? They should include both of those so make sure they’re updated if they don’t.
  • Stay Positive – Keep a positive attitude when addressing your stakeholders. We know this can be overwhelming to both you and them, but don’t let them see you sweat! Keep a positive approach with them and champion the imminent change.
  • Breathe – Yes, breathe. Use this change as a chance to perform internal checks and balances on your procedures and get various areas of your financial institution working together for a greater cause.

Our staff includes former bankers, regulators and fraud specialists so we know the stress you’re already under on a daily basis and making sure you’re in compliance with these new rules just adds to that. We’ve compiled a handy sample CDD checklist so you can make sure you’re doing everything you need to get your financial institution ready. Check out our Beneficial Ownership page, full of resources for both you and your staff. If you feel like you could still use some extra help, give us a call.

Our Professional Services team has a Beneficial Ownership Readiness Plan to help you approach the May 11th deadline feeling confident in your policies and procedures.

Your success is our number one priority so let’s work together to make sure you succeed! 

-Terri Luttrell, CAMS-Audit, Senior Manager of Consulting

Terri is a seasoned AML professional with over 20 years in the banking industry, working both in medium and large community and commercial banks ranging from $2 billion to $330 billion in asset size. She started her banking career in commercial lending, moving to deposit operations and the compliance/fraud arenas where she was Director and AML/OFAC Officer. She has successfully worked with institutions in implementing suspicious activity monitoring programs, installing various automated solutions, and streamlining processes while ensuring all regulatory requirements are met. She has also managed a team of AML investigators for a large/cross border institution giving her an enhanced sense of AML risk in our institutions. Since joining Banker’s Toolbox in 2012, Terri has used her extensive knowledge of BSA/AML Regulations as well as the FFIEC Exam Manual guidance to assist numerous clients in enhancing their suspicious activity monitoring program, improving written procedural practices, and evaluating the institution’s use of their automated systems. She conducts remote individual coaching sessions and group WebEx training sessions for clients based on their needs. Terri is a member of National ACAMS (Association of Certified Anti-Money Laundering Specialists) and is on the Board of the Central Texas ACAMS Chapter. She is CAMS-Audit certified.



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