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Daniel P. Stipano was quoted in ACAMS article, “Regulatory language may complicate enforcement of CDD Rule: Sources”


Daniel P. Stipano

Daniel P. Stipano was quoted on January 25, 2018 in an ACAMS article, “Regulatory language may complicate enforcement of CDD Rule: Sources,” which discussed the CDD rule and the contrasting regulations of the rule. The article stated, “Title 31, which transposes the Bank Secrecy Act and other laws into regulation, outlines the ‘four pillars’ of an anti-money laundering program, but was updated shortly after the CDD rule’s finalization to incorporate a ‘fifth’ pillar of compliance: appropriate risk-based procedures for ongoing customer due diligence. But banking regulators conduct their AML reviews under Title 12, which, along with the federal examination manual, still lists only the first four pillars mandated by the Money Laundering Control Act of 1986.”

Stipano noted, “The OCC possibly delayed officially adding a new, fifth pillar to avoid a formal rulemaking process that could have fueled perceptions of increased regulatory burden. I think it’s an optics issue. From an enforceability standpoint it adds nothing.”

Click here to read the full article.