The BSA Fifth Pillar: Helping You Prepare for Beneficial Ownership

“The BSA Fifth Pillar: Helping You Prepare for Beneficial Ownership by Asking These Simple Questions” by Bruce Zaret and Rachel Mondragon in Bankers Digest (April 10, 2017)

The Financial Crimes Enforcement Network (FinCEN) issued its final rule for Customer Due Diligence (CDD) under the Bank Secrecy Act (BSA) on July 11, 2016. It takes effect May 11, 2018.

The CDD requirement serves as the fifth pillar in the BSA’s efforts to combat money laundering involving financial institutions (FIs), adding to the existing four pillars which include: (1) written policies and procedures, (2) independent testing of the antimoney laundering (AML) program, (3) designation of the BSA officer, and (4) employee training.

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