TOPIC: Beneficial Ownership

New Loan - Existing Relationship

Director at a Company (USA)
     We are working on a new loan to an entity that is subject to the beneficial owner requirements. The beneficial owner has been identified as one of our existing customers. CIP was performed on the individual account in accordance with policy. However, the ID used expired in 2017. For the purpose of verifying the identity of the beneficial owner on the new loan, can I rely on the old expired DL or do I have to get a current ID since the information on file in not "up to date and accurate"? Side note - We went ahead and requested an updated DL to be on the safe side but the customer informed us that he does not have a new one. Should we allow this loan to open? What options do we have?

     Originally posted by an anonymous author with the title AVP Regulatory Compliance and Legal on 4 Mar 2019 to CBANC FI Professionals Community.

    CDD: One Year Later | Survey Request

    It's officially been one year since the CDD rule went into affect. Have you had an exam since then? What aspects of CDD and beneficial ownership, if any, did the examiner focus on? 

    We're doing a short survey on the impact CDD is having on recent exams and would appreciate if you could take a few minutes to fill it out. We're happy to share the results if you participate. 

    Thank you! 


      Case Study | Reducing Risk: Finding High-Risk Accounts & Preventing Fraud Losses in Real Time

      Case Study
      Reducing Risk: Finding High-Risk Accounts & Preventing Fraud Losses in Real Time

      Download the Case Study Now
      “With Verafin’s Private ATM Owner finder alerts, we discovered we actually had 45 [ATM owners]. It was eye opening that there were high-risk customers we didn’t know about.
      I am so glad that Verafin found these private ATM owners prior to our next exam. Not knowing … could have resulted in a finding, or worse, a fine for the bank.”

      Stacey Iverson, BSA and Fraud Officer, Bell Bank ($5.4B)
      When an examination in early 2018 reinforced the fact that Bell Bank ($5.4B) needed a more robust program for customer due diligence (CDD), enhanced due diligence (EDD) and identifying high-risk customers, the institution turned to Verafin to get prepared for Ultimate Beneficial Ownership, and strengthen their high-risk customer management and CDD/EDD processes.

      In this case study, you’ll read how BSA and Fraud Officer Stacey Iverson, and her team at Bell Bank, have increased confidence going into their next exam, thanks to the extra level of scrutiny that Verafin’s robust CDD/EDD solutions provide for identifying and managing their high-risk customers.

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