Buckley Sandler Webcast: CDD: Are You Prepared?
The applicability date for FinCEN’s Customer Due Diligence (CDD) rule is less than a year away. The rule codifies new and existing CDD requirements for covered financial institutions. While framed as an enhancement to existing CDD responsibilities, the rule requires financial institutions, for the first time, to collect and verify beneficial ownership information for most types of legal entity customers opening new accounts. The rule also adds a “fifth pillar” formalizing the requirement to develop and keep current customer risk profiles, and conduct ongoing monitoring.
The rule presents complex interpretation issues and implementation challenges. As banks and other covered institutions approach the applicability date, they need to focus on adapting their customer onboarding procedures to ensure that they are meeting the requirements of the new rule. Institutions that fail to achieve compliance by the applicability date are subject to supervisory and enforcement actions.
Please join Buckley Sandler and invited panelists for a discussion of the final CDD rule, the issues and ambiguities it presents, and practical advice for implementing the new requirements.
The discussion addressed the following topics:
- What should covered financial institutions be doing now to prepare for the May 2018 compliance deadline?
- How will the rule impact client acceptance procedures?
- What are the key issues and “gray areas"?
- To what extent can institutions rely on their customers' representations?
- The rule has been described as a floor and not a ceiling. In what circumstances would financial institutions be expected to go beyond minimum requirements?
- What types of circumstances would trigger an obligation to update customer information as part of the ongoing monitoring process, as contemplated in the rule?
- Daniel P. Stipano, Partner at Buckley Sandler LLP, brings more than three decades of bank regulatory and enforcement experience. Prior to joining the firm, Mr. Stipano was at the Office of the Comptroller of the Currency, where he served as Deputy Chief Counsel for 16 years. In his practice he advises on all aspects of bank regulatory and compliance issues
- Robert Rowe, Senior Counsel, Center for Regulatory Compliance, American Bankers Association
- Megan Hodge, Executive Compliance Director, BSA/AML Officer, Enterprise Compliance Regulatory Affairs, Ally Bank
- James T. Parkinson, Partner at Buckley Sandler LLP, focuses on international regulatory compliance counseling, corporate internal investigations, and enforcement defense litigation. He represents clients on a variety of criminal and civil enforcement actions, including Foreign Corrupt Practices Act, securities fraud, insider trading, false statements, and environmental matters
When: Thursday, June 15, 2017 from 12:00 - 1:00 pm EDT
Registration required. Please, no outside law firms, government agency personnel, consulting firms, or media. After registering and being approved, you will receive a confirmation email containing instructions for joining the webcast.