FinCEN’s final rule, “Customer Due Diligence Requirements for Financial Institutions,” became effective May 11, 2018.
Have you made all the changes necessary to incorporate this rule into your procedures? This checklist will help you think about areas you might have missed:
- Identify impacted lines of business.
- Update your Enterprise Risk Assessment and Customer Risk Assessment policies, such as your Customer Risk Rating Policy, Customer Acceptance Policy, Onboarding Policy and AML Risk Appetite Statement.
- Design new operational processes for this review, which requires a separate workflow from your OFAC 50% Rule and other processes (though it may leverage the same tools). This rule should be mentioned in some way in your processes for:
- Applications and forms
- Bank Secrecy Act
- New Account Opening / Onboarding / Customer Identification Program
- Anti-Money Laundering Transaction Monitoring
- Suspicious Activity Monitoring
- CTR Aggregation
- Implement any third-party solutions that can be used across these processes.
- Update your policies and procedures.
- Make sure you have a robust training plan and train your frontline and compliance employees.
How can LexisNexis Risk Solutions help?
As the march toward compliance with FinCEN’s Final Rule on Customer Due Diligence moves along, insurance carriers have many decisions to make and several preparations to get underway. LexisNexis® Risk Solutions can help evaluate your current position on the new requirements for determining and verifying beneficial ownership and chart a course forward that keeps the customer experience and core business operations at the forefront. We can help identify areas that need attention and assist in designing an identity verification strategy that seamlessly integrates into your customer onboarding workflows.
Reach out to your LexisNexis® representative to discuss how we can help.