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FinCEN CDD Rule

Keep it simple…there are two essential parts to this rule The first part (name of beneficial owners) is the basic data you need to capture in your core...

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FinCEN’s New CDD Rule & Significant and Unexplained Changes

April 16 2018 by Dave Gowan

FinCEN’s Final Rule regarding Customer Due Diligence (CDD) Requirements for Financial Institutions[1] (The New CDD Rule on Beneficial Ownership) is wrapped...

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High Risk Customers: Where to Begin

March 14 2018 by Dave Gowan

As a state or federally regulated financial institution, it’s important to have a grasp of what constitutes a high-risk customer as it pertains to BSA and...

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A Risk Model and Model Risk are not the sameā€¦

February 17 2017 by Dave Gowan

Model risk is defined by the Office of the Comptroller of the Currency (OCC) as “the potential for adverse consequences from decisions based on incorrect or...

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