Preparation Plan for CDD Changes to Beneficial Ownership Rules: Effective May 11, 2018

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This session will offer three important steps to prepare for the new beneficial ownership changes. The first step is creating a leadership group that establishes policy requirements and identifies all compliance requirements across lines of business. The second step is implementation design, which outlines the required processes and options for technology solutions. The third step includes appropriate training and new internal controls for the “fifth pillar” CDD requirements for “legal entity” accountholders. Join us to learn more about these significant changes and how to implement them.


  • New policy requirements that must be identified and revised
  • Four core elements of the CDD rules that must be included in the implementation design
    • Customer identification and verification
    • Beneficial ownership identification and verification of a “legal entity”
    • Understanding the nature and purpose of the relationship to develop a customer risk profile
    • Ongoing monitoring for suspicious transactions and maintaining and updating customer information
  • The preparation plan should include review of:
    • New account opening procedures
    • Suspicious activity monitoring procedures
    • CTR aggregation procedures
    • Onboarding processes, including eight important questions to update procedures
  • Training tips for the final rule, including customer education and potential form revisions for signature cards, certification forms, and worksheets
    • CDD checklists under the new rules
    • Template to develop a risk profile
    • Sample CDD policy
    • Template for identifying and verifying beneficial owners
    • Employee training log
    • Quiz you can administer to measure staff learning and a separate answer key


This informative session is designed for BSA officers, BSA staff, deposit operations personnel, loan operations staff, loan officers, risk managers, compliance officers, new accounts staff, and auditors.

ABOUT THE PRESENTER – Susan Costonis, CRCM, Compliance Consulting and Training for FIs

Susan Costonis is a compliance consultant and trainer who began her career in 1978.  She specializes in compliance management along with deposit and lending regulatory training. Susan has successfully managed compliance programs and exams for institutions that ranged from a community bank to large multi-state bank holding companies. She has been a compliance officer for institutions supervised by the OCC, FDIC, and Federal Reserve. Susan has been a Certified Regulatory Compliance Manager since 1998, completed the ABA Graduate Compliance School, and graduated from the University of Akron and the Graduate Banking School of the University of Colorado. She regularly presents to financial institution audiences in several states and “translates” complex regulations into simple concepts by using humor and real life examples.

Originally recorded on December 19, 2017.

Recorded webinar link is available until June 30, 2018.

Free Digital Copy included with purchase to download and view beyond link expiration date.

Price includes sales tax.