Gain an understanding of the requirements and related developments with FinCEN's new customer due diligence rules.
Banks and other financial institutions are required to identify and verify the identity of beneficial owners of legal entity customers under the Financial Crime Enforcement Networks' (FinCEN) new customer due diligence (CDD) rule. Many bank employees do not fully understand exactly when the CDD rule applies and what actions are required in order to satisfy their regulatory obligations. This topic helps the persons responsible for customer due diligence to understand which customers are covered by the CDD rule and which are excluded from the new requirements, as well as the specific information and documentation requirements for banks. It also guides banks in developing and implementing ongoing anti-money laundering policies to comply with FinCEN rules, including CDD requirements. This information is also critical for legal entity customers to understand their disclosure obligations when beginning new banking relationships, including in corporate transactions.
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Why Lorman?
Over 34 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.
Agenda
Identifying Beneficial Owners
- Beneficial Owner Definitions and Thresholds
- Exclusions to Definition of Legal Entity Customer
- Complex Ownership and Control Structures
Verification and Documentation of Beneficial Owners
- Existing Customers vs. New Customers
- Product or Service Renewals
- Completing CTRs
Bank Policies and Procedures
- Risk-Based Determinations More Stringent Than CDD Rule
- Beneficial Ownership Certification Form
- Updating and Monitoring Customer Information
AML Program Requirements
- Nature and Purpose of Customer Relationship
- Ongoing Monitoring
- Updating Customer Information
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Why Lorman?
Over 34 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.
Credits
OnDemand Course
This course was last revised on April 30, 2019.
Call 1-866-352-9540 for further credit information.
This program does NOT qualify, nor meet the National Standard for NASBA accreditation.
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Why Lorman?
Over 34 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.
Faculty
V. Gerard Comizio
Fried, Frank, Harris, Shriver & Jacobson LLP
- Partner in the corporate department and chair of the banking practice, resident in Fried, Frank, Harris, Shriver & Jacobson LLP’s Washington, DC office
- Practice emphasizes all aspects of financial services matters
- Conducts regular seminars and workshops and has written numerous articles analyzing current issues in financial services regulation, and is an author or contributing author of four books on financial services matters
- Member, Law360 International Trade Editorial Advisory Board (2018-2019); Board of Advisors of the University of North Carolina Law School Center for Banking and Finance; Governing Committee of the U.S. Conference on Consumer Financial Law; Trusts and Investments Subcommittee, American Bar Association, 2005-2006; (Former) Member, Advisory Board, George Washington Law School Center for Law, Economics and Finance; Deputy Chair, Gifts For The Homeless; Member, Board of Visitors, Pace University (Elizabeth A. Haub) Law School
- Recognized in Chambers USA: America's Leading Lawyers for Business as a leading individual in Financial Services Regulation: Banking (Compliance) and also recognized by Legal 500
- LL.M. degree, Georgetown University Law Center; J.D. degree, Pace Law School; B.A. degree, Fordham University
- Can be contacted at [email protected] or 202-639-7450
Michael T. Gershberg
Fried, Frank, Harris, Shriver & Jacobson LLP
- Partner in the corporate department and U.S. head of the international trade and investment practice, resident in Fried, Frank, Harris, Shriver & Jacobson LLP’s Washington, DC office
- Practice emphasizes all aspects of international trade and investment law
- Conducts regular seminars and workshops and authors publications related to the areas of economic sanctions, anti-money laundering, export controls, and foreign investment
- Member, Law360 International Trade Editorial Advisory Board (2017-2019)
- Recognized in Chambers USA: America's Leading Lawyers for Business as a Recognized Practitioner in International Trade: CFIUS Experts and also recognized in the Foreign Investment Review chapter of Who’s Who Legal: M&A and Governance
- J.D. degree, cum laude, Harvard Law School; B.A. degree, magna cum laude, Yale University
- Can be contacted at [email protected] or 202-639-7085
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Why Lorman?
Over 34 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.
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