Three things you need to stay compliant.
Customer Due Diligence has always been a topic of discussion, however, when FinCEN announced the requirement to obtain beneficial ownership information in 2016, this topic became the main point of focus for many in the BSA/AML industry. With the new Customer Due Diligence (CDD) rule in effect, financial institutions have been working tirelessly on collecting beneficial ownership information. While beneficial ownership is a major focal point, it is still very important to remember all that CDD entails. Have you thought about all of your customers/members with elevated risk categories? Are you doing enough enhanced due diligence (EDD) on them?
Most BSA professionals tasked with EDD have inherited the program from their predecessor. Like your grandma’s fine china that was passed down to you, it may be best to keep some things in the past. The bones of your current EDD program might be fine, but with so many technological and regulatory changes, it is important to take a step back and look at the big picture to see where you can create efficiencies within your program. When revising your EDD program, it is crucial to consider these three things: