Shedding Light on the Regulatory Landscape: CAST Co-Hosts Its Second Beneficial Ownership Symposium
CAST Management Consultants continues to take a leading role in understanding best practices and hurdles that banks face when looking to implement the new Beneficial Ownership regulation as part of their overall Know Your Customer (KYC) programs. In order to facilitate an open dialog within the banking industry, CAST, in conjunction with First Republic Bank, co-hosted a symposium on Beneficial Ownership in late 2016. CAST’s Regulatory Compliance and Risk practice specializes in operationalizing compliance programs by working across Lines of Business, Middle Office, and Risk and Compliance teams to implement integrated regulatory and risk solutions.
This was the second symposium held on the topic of Beneficial Ownership and was a bicoastal event held simultaneously in New York City and San Francisco. More than 30 participants from Compliance, Risk, Legal and Lines of Business, representing different peer banks attended the discussion and contributed to a valuable dialog on plans and preparations that are underway to comply with the new Beneficial Ownership rule that FinCEN published in May of this year. The topics discussed ranged from what information needs to be collected from clients and beneficial owners of accounts, to the monitoring of accounts and aggregating of transactions to file CTRs and SARs.
The complete list of topics covered during this four hour event included:
- CIP & CDD Requirements
- CIP Verification
- Certification Form for Beneficial Ownership
- Entity Structures & Client Hierarchies
- Trigger & Refresh Events
- Screening Beneficial Ownership Information
- Monitoring Beneficial Ownership Information
- Exclusions from Beneficial Ownership Requirement
- Technology Implications
Of particular interest to the group was the certification of information that will now be required to open an account on behalf of an entity. Questions were raised regarding authorized signers, the frequency with which these documents were needed, as well as privacy concerns when the information needs to be updated. Overall, the attendees agreed that taking a risk-based approach to all the topics would be in the best interest of the institutions.
The symposium provided participants an opportunity to understand what their peers are doing so that they may consider similar approaches as their institutions look to comply with the new regulation by the May 2018 deadline. As a result, the participants in the symposium expressed strong interest in continuing the open dialog on beneficial ownership as well as other topics. CAST will explore additional events and topics in 2017 and look to host a follow-up to the symposium.
If you or a colleague are interested in finding out more about these future beneficial ownership discussions or CAST’s Regulatory Compliance and Risk Practice, please contact Dana Twomey, a Director with CAST here.
CAST [Center for Applied STrategy] provides consulting services that drive sustainable performance improvement. For more than 30 years we have been committed to delivering implementable solutions tailored to meet the unique needs of our clients. Our deep industry knowledge coupled with our fact-based, data driven approach provides our clients with meaningful insights into their organizations.
CAST’s Regulatory Compliance and Risk practice works across Lines of Business, Middle Office, and Risk and Compliance teams to provide integrated regulatory and risk solutions. Leveraging deep industry expertise and a highly collaborative approach, we assist clients in operationalizing effective compliance and risk programs through enhanced training and communications, governance, technology implementation, process and procedures development, and reporting.