potentially burdensome customer due diligence (CDD) regulation is moving
forward, we aren’t expecting to see a compliance date anytime soon. FinCEN is
currently recommending an effective date one year after the final rule is
position that CDD consists, at a minimum, of four elements:
- Identifying and verifying the identity of credit union
- Identifying and verifying the identity of beneficial
owners of legal entity members;
- Understanding the nature and purpose of member
- Conducting ongoing monitoring to maintain and update
member information and identify and report suspicious activity.
This proposed regulation may have a
significant impact on your BSA compliance.
This is your opportunity to influence the final compliance
requirements. Comments are due in early
October. For more information on the comment process go to cuna.org/powercomment.