In May of 2018, the Bank Secrecy Act’s “fifth pillar,” Customer Due Diligence and Beneficial Ownership became effective.
Banks created policies and procedures to comply with the rules to identify beneficial owners of business entities and to truly know their customers and the transactional activity they should expect to see from those customers. While the requirements of these rules were quite extensive and created a lot of extra paperwork, banks did a great job of complying.
However, it has been almost three years now and we have heard from compliance professionals and auditors that some banks are starting to slack a bit in this area. It’s fair to surmise that bankers may be losing focus because they are busy keeping up with new rules. It’s also possible that bankers were hearing about and hoping for regulatory changes and decided to adopt a wait and see posture.
In December 2020, the Anti-Money Laundering Act of 2020 was passed by Congress. Part of the Act required FinCEN to develop a system in which businesses will need to register their beneficial owners with them rather than the bank having to collect, document, and verify.
This will take several years to implement. So, in the meantime, banks must continue to comply with the requirements of the Bank Secrecy Act regarding beneficial ownership. So, due to the increase in the number of beneficial ownership findings/violations and the fact that the regulation will not change for some time, now is the time to refresh your new account personnel (both deposits and lending) on the rules.
Enroll them into our updated Bank Secrecy Act–Customer Due Diligence and Beneficial Ownership course today.
On March 23 we launched new versions of the following Bank Secrecy Act courses:
While the existing version of each of these courses is not incorrect, we highly suggest you unenroll them in the existing version and enroll them. The existing versions will not be maintained in the future if the regulation changes.
Premium Plan subscribers: No action is required on your end for your employees to get these new course versions. On April 1, 2021 we will load the new courses into any current enrollments, certificates, catalogs etc. so that the new version will automatically launch.
Custom Plan subscribers: The new Bank Secrecy Act–Customer Due Diligence and Beneficial Ownership now has three places within the course in which you can upload your banks specific policies and procedures regarding the content contained in the specific page. This is listed out separately within the system. If you have any questions about the functionality, please contact us.
Launching on March 31st are the following NEW cyber courses:
Review the Detailed Course Catalog for course descriptions.
Premium Plan subscribers: The new cyber courses are not automatically placed into your catalog of courses. You can modify catalog names, add or remove catalogs and fully control which courses are displayed within each catalog. Many of the Premium Plan clients have customized the catalogs based on their needs. Because of this ability to customize, when new courses are added to the LMS, they are not automatically added into a catalog. This function is left to the LMS administrator to place the course in the specific catalog based on their bank's needs. To help with this process, we have included instructions on adding a course into a catalog of your choice. If you have any questions, reach out to Vubiz for technical assistance.
The following courses will be updated with fresh content in early – to mid – April:
These updated courses will not require any administrative work as those currently enrolled and not completed will receive the new content. Please watch the “What’s New” tab for the launch date.
Did you know that you can get up-to-date catalog and course changes without waiting for this monthly online newsletter? Simply log into the Online Training Center and click on the “What’s New” tab on a regular basis. A real-time PDF resides here with all the catalog changes made over the past years.