Buckley Sandler Webcast: The CDD Rule is almost here: Are you ready?
Regulators gave financial institutions two years to get ready for new requirements that promised to fundamentally change the procedures they use to gather information about the one thing that is central to all of their business models: customers. In preparation for the May 11 implementation of the Customer Due Diligence Rule, many covered financial institutions have upgraded their technology, systems, procedures, and training to accommodate the changes it will bring.
Their efforts, however, have not guaranteed peace of mind. Prudential regulators have already signaled their intention to begin examining banks for compliance shortly after the effective date, but neither they nor FinCEN have issued any examination procedures or meaningful guidance on the rule itself. Given the policy goals of the new rule, regulators will have high expectations for institutions of all size.
Buckley Sandler and invited panelists discussed 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 to prepare for the May 11 compliance deadline?
- What areas are examiners most likely to focus on when they assess compliance?
- When will examiners expect financial institutions to go beyond minimum requirements?
- What changes are expected to onboarding procedures, Customer Due Diligence and Enhanced Due Diligence, Customer Identification, IT, vendor management, etc.?
- How best to address the key issues and “gray areas"?
- What are expectations with respect to SARs, CTRs, OFAC, and 314(a)?
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.
Rick Small, Executive Vice President, Director Financial Crimes Program, BB&T, brings leading insights on the challenges, strategies, regulatory expectations and future focus areas for anti-money laundering and financial crimes at a global level. His experience includes overseeing the enterprise-wide anti-money laundering, anti-corruption and sanctions programs in the United States and abroad.
John Byrne, CEO, Condor Consulting, former Executive Director of ACAMS, is a nationally known regulatory and legislative attorney with close to 30 years of experience in a vast array of financial services issues, with particular expertise in all aspects of regulatory oversight, policy and management, anti-money laundering (AML), privacy, and consumer compliance.
Lauren Kohr, Senior Vice President & Chief Risk Officer, Old Dominion National Bank, is responsible for Old Dominion's corporate-wide operational risk management program, including leading the bank's Anti-Money Laundering (AML), Bank Secrecy Act (BSA) and Office of Foreign Asset Control (OFAC) policy and governance. She is a highly experienced risk management professional who has been recognized by her peers in the industry for her excellence in administering industry leading BSA, AML, and OFAC programs.
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.