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.
I spoke this week to John Arvanitis about the new rules. He’s an Associate Managing Director of Kroll based in New York City.
He joined Kroll after a 27-year career with the Drug Enforcement Administration.
In our interview, John 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 our 14-minute discussion:
Richard Bistrong is a contributing editor of the FCPA Blog and CEO of Front-Line Anti-Bribery LLC. In 2010 he pleaded guilty to a conspiracy to violate the FCPA and served fourteen and a half months at a U.S. federal prison camp. He was named to Compliance Week’s list of Top Minds in 2017 and was one of Ethisphere’s 100 Most Influential in Business Ethics in 2015.
His popular real-life compliance training video, Behind the Bribe, produced in cooperation with Mastercard, was released in 2017.
To request a demo of the full eleven-minute video or a licensing fee schedule, please click here.