Financial institutions have been implementing new regulations through board-approved policies for decades. As existing regulations are revised and new regulations are published existing polices need to be updated. Policy Updates are designed to simplify the task of updating existing policies, regardless of where the existing requirement is lodged. Policy Updates include a summary of the requirement and address procedures, training and testing.
FinCEN issued final rules under the Bank Secrecy Act to clarify and strengthen customer due diligence requirements for banks, brokers or dealers in securities, mutual funds, futures commission merchants and introducing brokers in commodities. The rules contain explicit customer due diligence requirements and includes a new requirement to identify and verify the identity of beneficial owners of legal entity customers, subject to certain exclusions and exemptions.
The 2016 Beneficial Ownership Rules Policy Update communicates the Board’s intent to comply with the beneficial ownership requirements.