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 when opening a new legal entity account (aka business account) and apply the same KYC checks you do for other members
The second part is the FinCEN AML Program Requirements for CDD to capture information about your business accounts and use that for risk based monitoring and risk rating
To solve part A, in your core application…
Collect the name and identity information for individuals owning 25% or more of legal entities (aka business accounts), such as SSN, driver’s license, passport, or other government issued ID. Enter this data in your core processing system and apply your standard member verification (i.e., sanction checks, identity verification, soft credit check, etc.) against these individuals. This is required for business accounts opened after May 11, 2018.
To solve part B, use the SimpliRisk EBAM service...
The Enhanced Business Account Monitoring (EBAM) service from Pay Lynxs' SimpliRisk compliance automation product has everything you need to setup and support your FinCEN required CDD program to meet the new AML Program Requirements. EBAM offers a complete risk-based approach to support the CDD requirements:
The EBAM module creates a business profile including:
The nature of the business
Transaction volume and frequency expectations (ACH, Wire, Cash, Check, etc.)
NAICS code for peer grouping and risk rating
Products to be used by the business
Using the EBAM profile, the SimpliRisk transaction monitoring service will track your business accounts and provide alerts when activity exceeds the baseline expecations established in the profile
The EBAM serivce will also risk rate business accounts using several factors, including the EBAM profile information, so you can identify your high-risk members easily and concentrate your reviews on these accounts
Using the EBAM Collection and Import service you can capture information electronically from your existing business accounts and bulk import into SimpliRisk
Check out our product video for SimpliRisk EBAM for the FinCEN CDD rule. Contact us to learn more.