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FinCEN’s Temporary Relief for Autorenewable CDs and Loans

May 30, 2018

Authors

Barry Hester

FinCEN’s Temporary Relief for Autorenewable CDs and Loans

May 30, 2018

by: Barry Hester

In a unique administrative ruling under delegated “exceptive” authority, on May 16, 2018 FinCEN issued relief from its new beneficial ownership requirements through at least August 9, 2018, for “certain financial products and services that automatically rollover or renew (i.e., certificate of deposit (CD) or loan accounts) and were established before the Beneficial Ownership Rule’s Applicability Date, May 11, 2018.”

FinCEN acknowledged in its notice that “some covered institutions have not treated such rollovers or renewals as new accounts and have established automatic processes

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Regulators Update BSA/AML Exam Manual Sections

May 15, 2018

Authors

Barry Hester

Regulators Update BSA/AML Exam Manual Sections

May 15, 2018

by: Barry Hester

Just in time for the effective date of FinCEN’s Customer Due Diligence (CDD) and Beneficial Ownership Rules, on May 11, 2018 the Federal Financial Institutions Examination Council (FFIEC) published updates to its Bank Secrecy Act/Anti-Money Laundering Examination Manual.  The FFIEC is an interagency body comprised of representatives of the U.S. Federal Reserve Board, the FDIC, OCC, CFPB, NCUA, and state banking regulators.  The agencies’ changes (1) replace existing CDD sections of the manual and (2) add new Beneficial Ownership overview and exam procedures sections, in each case corresponding to the new CDD and Beneficial Ownership requirements.

The publication of this new content was announced through separate press releases by

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FinCEN Provides Relief to CDD Obligations for Existing Customers

April 5, 2018

Authors

Barry Hester

FinCEN Provides Relief to CDD Obligations for Existing Customers

April 5, 2018

by: Barry Hester

The Financial Crimes Enforcement Network (FinCEN) published long-awaited additional Frequently Asked Questions on April 3, 2018 (the “Guidance”) relating to its Customer Due Diligence (CDD) Rule, which FinCEN promulgated pursuant to the Bank Secrecy Act (the “CDD Rule”).  This comes at a time when most covered institutions are in the final stages of implementing plans to comply with the CDD Rule by its May 11, 2018 compliance applicability date.  FinCEN previously published technical amendments to the Rule on September 29, 2017

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