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1:30pm to 3:30pm |
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CIP, Customer Due Diligence and Enhanced Due Diligence
(Presented By: Ken Golliher)
BSA's new focus is at account inception - does your new accounts process measure up? Are you asking the right questions? Getting the right information? Drawing the right conclusions?  | WEBINAR TIME:
11:30AM - 1:30PM PT
12:30PM - 2:30PM MT
1:30PM - 3:30PM CT
2:30PM - 4:30PM ET |
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 |  | WHAT?
Now, there is a new hierarchy of information requirements associated with account opening. It carries over to account monitoring after the account is established. Banks must obtain specific information required by law in their Customer Identification Program (CIP). From there, they move up to Customer Due Diligence and then Enhanced Due Diligence. Each regimen is a critical pulse point in the evaluation of any BSA compliance program and a key term in the revised BSA examination procedures.
WHY?
Banks are expected to identify persons and entities of interest to their BSA/AML compliance efforts. The easiest time to identify them is at account opening. What questions should your bank ask to identify:
nonresident aliens and foreign individuals,
politically exposed persons,
embassy and foreign consulate accounts,
non-bank financial institutions,
professional service providers,
non-governmental organizations and charities,
corporate entities (domestic and foreign), and
cash intensive businesses?
Once you have identified them, what do you ask next? What documentation and monitoring efforts is the bank committed to if it opens the account? Should the bank open the account?
Decisions to open new accounts, assign risk ratings, determine appropriate levels of monitoring, file suspicious activity reports and unilaterally close accounts are all based on information. Decisions are either based on facts the bank has or facts which it assumes. However, if the bank does not have an adequate amount of data, it makes crucial decisions based on pure guesswork. This webinar is about asking the right questions and using the information obtained correctly.
PROGRAM CONTENT?
CIP requirements
Revised CIP Q & A
CIP examination procedures
Identifying and working out CIP glitches
Setting due diligence priorities based on the results of the risk assessment
Due diligence vs. know your customer
Scaling due diligence to the proposed relationship
Recognizing potential high risk customers at account inception
Customer acceptance policies
Documentation requirements at account inception
Scaling due diligence to the bank's ability to monitor the relationship
When is enhanced due diligence necessary?
Monitoring as the continuation of due diligence and enhanced due diligence
Documentation requirements over the life of the account
WHAT DO YOU WANT TO HEAR ABOUT DURING THE WEBINAR?
There will be Q & A's during the program, but if you want to submit questions in advance or make certain your topic is addressed, send them to seminars@bankersonline.com Put "CIP/Due Diligence" in the message line.
WHO?
The program is designed for operations personnel as well as BSA officers and auditors employed by banks, thrifts and credit unions. It focuses on specific elements of Bank Secrecy Act compliance and compliance management, not the regulation in its entirety.
The Speaker:
Ken Golliher is a principal with Pegasus Educational Services, LLC, a training firm headquartered in Louisville, Kentucky. He is an experienced banker with a unique ability to reduce complex legal concepts to plain English. He has explained the "why" and "how" of regulations to thousands of financial institution personnel and examiners. Ken's banking career began in 1972 and includes serving as a teller, commercial operations manager and as trust department legal counsel in a state and a national bank. For ten years he headed the education division of a regional consulting firm for financial institutions. He has served on the faculty of the LSU Graduate School of Banking, the OTS' Level I Compliance School and the FDIC's Advanced Consumer Protection School for examiners. He has presented seminars in more than 25 states and has served as an instructor at compliance schools sponsored by the Illinois, Indiana, Georgia, Kansas, Kentucky, Nebraska, Pennsylvania and Texas bankers associations. He is one of the moderators for the Bank Secrecy Act forum at http://www.bankersonline.com More information...
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