WHAT?
Recent Interagency Guidance clearly indicates banks should identify the "beneficial owners" for higher risk customers through their due diligence processes. Banks that have followed the practice for years refer to it as "drilling down," attempting to identify their real customers; i.e. the individuals who control the business. This element of "due diligence" is one of the key components of every bank's anti-money laundering program. It supplements the bank's customer identification program and paves the way for enhanced due diligence when necessary.
WHY?
Banks are expected to identify persons and entities of interest to their BSA/AML compliance efforts. The easiest time to identify them is at account opening. What questions should your bank ask that would allow it to identify:
- nonresident aliens and foreign individuals,
- politically exposed persons,
- embassy and foreign consulate accounts,
- non-bank financial institutions,
- professional service providers,
- non-governmental organizations and charities,
- corporate entities (domestic and foreign), and
- cash intensive businesses?
Once you have identified them, what do you ask next? Should you even open the account? If you do, what documentation and monitoring efforts is your bank committed to if it opens the account?
Decisions to open new accounts, assign risk ratings, determine appropriate levels of monitoring, file suspicious activity reports and unilaterally close accounts are all based on information. Decisions are either based on facts the bank has or facts which it assumes. However, if the bank does not have an adequate amount of data, it makes crucial decisions based on pure guesswork. This webinar is about asking the right questions and using the information obtained correctly.
PROGRAM CONTENT?
- CIP requirements
- Common CIP enhancements
- CIP examination procedures
- Identifying and working out CIP glitches
- Setting due diligence priorities based on the results of the risk assessment
- Due diligence vs. know your customer
- Scaling due diligence to the proposed relationship
- Identifying beneficial owners (point of emphasis in the program)
- Recognizing potential high risk customers at account inception
- Customer acceptance policies
- Documentation requirements at account inception
- Scaling due diligence to the bank's ability to monitor the relationship
- When is enhanced due diligence necessary?
- Monitoring as the continuation of due diligence and enhanced due diligence
- Documentation requirements over the life of the account
Who Should Attend?
The expected audience is frontline personnel who routinely open deposit accounts for businesses and those who supervise this function. Calculate the per person costs for providing every one of your staff members who opens new accounts with a professional training program. (Remember, when you attend BOL webinars, not all of your employees have to be available the day of the program - you can access it again for up to 30 days after the program.)
The program will also benefit those who audit or review the account opening process for quality control. Program content is at the basic or intermediate level. Program content does not reflect the laws of a particular state.