Risk and compliance professionals in commercial and merchant acquiring banks should clearly understand the requirements imposed on covered financial institutions (CFIs) of FinCEN’s Final Rule for Customer Due Diligence (CDD) published in May of 2016.


The Beneficial Owners Rule, as it is often called, leaves many banks unclear about how they should implement new guidelines within their risk-based customer due diligence procedures. Many CFIs are unsure about the self-certification aspect of beneficial owners information and how often this information should be updated. Additionally, many are unsure about the procedures regulators will expect them to undertake within their beneficial owners program by the May 11, 2018 compliance date.


This white paper addresses program weaknesses and procedures CFIs should strive towards when implementing what has now become known as the 5th pillar of BSA/AML programs.

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