It’s crunch time for BSA’s new CDD rule

by Marina Hernandez

The May 11, 2018 date for compliance is only a month away! Did you cross all the t’s and dot all the i’s? Here are three good questions from our Compliance Hotline. Check them out so you can confidently say you have addressed them in your own CDD Checklist for compliance.

1.) Should I run OFAC Checks on Beneficial Owners?

Yes, you should run OFAC on beneficial owners, that is why we are collecting this information in the first place. We want to be able to take appropriate action on the legal entity if there is a hit. The same goes for 314(a) scans: scan the beneficial owners for a named match, but you do not need to report the underlying beneficial owners if only the legal entity is a named subject match.

 

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