On May 11, FinCEN's Final Rule regarding customer due diligence went into 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:
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Customer identification and validation beneficial ownership identification and verification
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Understanding the nature and purpose of customer relationships to develop a customer risk profile
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Ongoing monitoring for reporting suspicious transactions, and
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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.
