The March 15 deadline for FinCEN’s final rule is fast approaching. Is your business prepared to comply with the new expectations? This blog highlights the key considerations to be aware of in evaluating your current due diligence program.
Recognize AML and BSA risk across the entire customer relationship
Our recent blog post outlined the previously exempt financial institutions impacted by the FinCEN final rule. These institutions have until March 15, 2021 to establish and implement customer identification programs (CIP) and anti-money laundering (AML) programs that align with Bank Secrecy Act (BSA) expectations. The FinCEN final rule is built around the inherent expectation for your organization to truly know your customer and fully understand the AML and BSA risks they may pose to your business across the entire lifecycle of the relationship. The FinCEN final rule increases due diligence demands, but there are ways to simplify compliance.
Start with a comprehensive customer identification program
A robust customer identification program that aligns with Section 326 of the USA PATRIOT Act is at the core of a strong AML/BSA compliance strategy. Our FinCEN Final Rule tip sheet lists the steps to confirm your customer identification program meets the complete regulatory requirements. Be confident that you can easily demonstrate that you have verified the true identity of each customer you serve. To further streamline compliance, ensure your customer identification program is optimized to function effectively across remote and in-person service channels.
Make the five pillars a focused priority
Your organization may already have many elements in place to follow the regulatory requirements of the Bank Secrecy Act. The fifth pillar represents FinCEN’s Customer Due Diligence (CDD) Rule which is fully outlined in our FinCEN Final Rule tip sheet and may warrant extra attention. Plan ahead now by assessing your current due diligence workflows against these expectations and actively selecting resources to help complete enhanced due diligence and manage the CDD Rule’s Beneficial Ownership requirements.
Add the advantage of automation
Automating your customer identification program and customer due diligence workflows can save time and help offset increased resource demands. Utilizing quality risk intelligence to support due diligence efforts can also improve efficiencies: starting with comprehensive, current and easy-to-consume information reduces decision delays and helps quickly resolve investigations. Take time to identify any disparities across your current due diligence strategy, compliance technologies and data sources. Incorporate greater levels of efficiency into your program by identifying solutions that provide long-term value and can be tailored to meet specific risk tolerances.
Benefit from a robust AML and BSA compliance program
Compliance with FinCEN’s final rule is critical to avoid reputational damage and regulatory fines that can easily derail your business goals. Stronger compliance not only protects your business; it can also drive deeper risk visibility and reveal customer opportunities. By proactively evaluating your current due diligence program, you can identify the most impactful steps to help meet FinCEN expectations and take the opportunity to strengthen the overall efficiency and effectiveness of your entire AML/BSA compliance program.
Ready for the FinCEN final rule? We can help your business fully optimize your compliance program to take advantage of the benefits of automated due diligence workflows and improved risk visibility at the enterprise level.
Download our FinCEN Final Rule tip sheet here and connect with us to learn more.