Bank, credit union regulators issue exam procedures on FinCEN’s CDD rule

Examination procedures for assessing compliance with a new Bank Secrecy Act (BSA) “customer due diligence” rule that took effect Friday – requiring covered institutions to verify the identity of beneficial owners at account opening – were issued the same day by bank and credit union regulators through the umbrella Federal Financial Institutions Examination Council (FFIEC).

The council says the examination procedures, which focus on the CDD rule issued by the Financial Crimes Enforcement Network (FinCEN), apply to banks, savings and loan associations, savings associations, credit unions, and branches, agencies, and representative offices of foreign banks. They replace those in the current “Customer Due Diligence — Overview and Examination Procedures” section of the FFIEC’s Bank Secrecy Act/Anti-Money Laundering Examination Manual. In addition, a new overview and examination procedures were developed for the beneficial ownership requirements for legal entity customers.

FFIEC member agencies created these procedures in close collaboration with FinCEN and the U.S. Department of the Treasury.

The new exam procedures were also circulated Friday by the bank and credit union agencies.

The FFIEC includes representatives from the Federal Reserve Board (Fed), Office of the Comptroller of the Currency (OCC), Federal Deposit Insurance Corp. (FDIC), National Credit Union Administration (NCUA), the State Liaison Committee (SLC), and Bureau of Consumer Financial Protection (BCFP).

Customer Due Diligence – Overview and Examination Procedures (PDF)

Beneficial Ownership for Legal Entity Customers – Overview and Examination Procedures (PDF)

FDIC FIL-26-2018

OCC Bulletin 2018-12

NCUA announcement