Daniel P. Stipano quoted in ACAMS article, “FinCEN emphasizes CDD rule’s focus on risk, risk … and risk”
ACAMSDaniel P. Stipano
Daniel P. Stipano was quoted on August 3, 2020, in an ACAMS article, “FinCEN emphasizes CDD rule’s focus on risk, risk … and risk,” which discussed guidance from FinCEN that financial institutions should screen new and existing clients under the CDD rule that accounts for the institution’s individual level of risk.
Stipano noted, “Rather than break new ground, Monday’s guidance further underscores that financial institutions should tailor their controls to their unique products, customers and geographies. It dovetails with the emphasis on risk-based procedures set forth in the recent revision to the FFIEC manual and other agency pronouncements.”
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