Examiners frequently criticize financial institutions for failure to provide adequate training for the board of directors and senior management. Experience shows this audience is not likely to sit through an extended training session on compliance-related matters, but training in small doses works well. Director/Senior Management Updates (DSMU) can be delivered to directors and senior managers for individual review or can serve as the basis for a brief training session.
New BSA rules were effective July 11, 2016 with compliance mandatory May 11, 2018 relating to customer due diligence rules for beneficial owners of legal entity customers. The 2016 Beneficial Ownership Rules DSMU contains pertinent information for Directors and Senior Management including an explanation of the issue, a summary of the requirements, the effective date, an initial risk assessment, and action requested of management.