John Arvanitis: Complying with FinCEN's new customer due diligence rules

John Arvanitis: Complying with FinCEN's new customer due diligence rules

April 13, 2018

On May 11, FinCEN's Final Rule regarding customer due diligence will be in force. That means covered financial institutions will have to make sure their due diligence programs are in line with FinCEN’s guidance on core elements of a customer due diligence program.

Those four core elements include:

  • Customer identification and validation beneficial ownership identification and verification
  • Understanding the nature and purpose of customer relationships to develop a customer risk profile
  • Ongoing monitoring for reporting suspicious transactions, and
  • On a risk-basis, maintaining and updating customer information.

Kroll’s John Arvanitis recently sat down with Richard Bistrong for the FCPA Blog to discuss the new rules.

In their interview, John and Richard also talked about the challenges of identifying and verifying beneficial owners, as surveyed in the recently released 2018 Kroll-Ethisphere Anti-Bribery Corruption and Benchmarking Report, which can be downloaded here.

Here's their 14-minute discussion




John Arvanitis is an Associate Managing Director in Kroll’s Compliance practice, based in the New York Office. John advises clients worldwide on anti-money laundering matters and other aspects of compliance programs, bringing impactful and valuable insight to their challenges via his extensive international and domestic financial investigative experience. He has significant experience across a broad range of compliance-related programs, including anti-money laundering, know your customer, global AML processes, and program and policy formation.

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John Arvanitis