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The Customer Due Diligence Requirements for Financial Institutions released by the Financial Crimes Enforcement Network (FinCEN) last year will go into effect in 2018. 2017 will be the year that many institutions prepare for these new regulations. Processes and technologies will need to be evaluated to ensure that they are in line with the new rules. Booz Allen’s riskCanvas™ software can help institutions achieve compliance.
Every financial institution in the United States is currently reviewing its customer due diligence (CDD) processes to ensure compliance with new requirements from FinCEN. The most high-profile requirement surrounds identifying the beneficial owners of all legal entity customers, but the rule also reinforces the importance of customer identification verification, understanding the nature and purpose of customer relationships, developing customer risk profiles, and using risk-based rules for maintaining and updating customer information.
All of these requirements add up to financial institutions needing to not only collect and maintain better customer records, but also to determine better ways to use this information in anti-money laundering (AML) compliance. It is not enough to just add new fields on your account application; collecting customer information is the (relatively) easy part. Figuring out how to use that information and effectively integrate it into the compliance process is far more challenging. Without the proper procedures and tools in place, come May 2018 when the rule goes into effect, financial institutions will find themselves swimming in newly collected customer information but ultimately may not actually be in compliance with the new requirements.
At the heart of the new FinCEN rule is the idea that financial institutions not only know their customers but also understand their customers. To become compliant, data collections must be fully integrated into the CDD process and used to create a complex, multi-dimensional view of the customer that updates based on changing circumstances. Customer profiles must dynamically account for the inherent risk from linked persons and entities, such as beneficial owners, and vice versa. And CDD rules can no longer be one-size-fits-all but instead should automatically adjust based on varying levels of customer risk.
The Customer Due Diligence (CDD) Requirements for Financial Institutions released by the Financial Crimes Enforcement Network (FinCEN) last year will go into effect in 2018. Learn how Booz Allen’s riskCanvas™ software can help institutions prepare for these new regulations.