Credit unions now have less than six months to come into compliance with the Financial Crimes Enforcement Network's (FinCEN) Customer Due Diligence (CDD) rule, effective May 11, 2018. CUNA has developed a number of tools to assist credit unions, including a CDD checklist, final rule summary and CDD compliance chart.
The rule includes provisions that address identifying the beneficial owners of legal entity accounts and financial institutions’ anti-money laundering (AML) programs.
New beneficial owner requirements include:
New AML requirements include:
NCUA’s Bank Secrecy Act (BSA)/AML regulations currently require the first four bullets, and the fifth bullet reflects existing practices necessary to satisfy suspicious activity reporting (SAR) obligations.