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Train Your Team on Customer Due Diligence and Beneficial Ownership with this BSA Compliance Rap!

Train Your Team on Customer Due Diligence and Beneficial Ownership with this BSA Compliance Rap!

Posted by Kinsey Sullivan on Feb 14, 2018 8:00:00 AM
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One incredibly creative and clever compliance professional posted this helpful, fun rap about CDD requirements online. Read her training rap, and learn more about Customer Due Diligence requirements here.

In May 2016, the regulators at FinCEN released new Customer Due Diligence (CDD) requirements, now known as the Fifth Pillar of BSA/AML Compliance. This CDD Final Rule rule strengthens the existing requirements, and requires financial institutions to identify and verify the beneficial owners of legal entity customers.

All covered financial institutions need to be prepared to be fully in compliance with this final rule by May 11, 2018. Get this free guide to the fifth pillar of BSA/AML compliance to learn more.

As we were researching the CDD Rule, we came across an incredible resource from Anita Garrett, CRCM, SVP and Sr. Compliance Officer at the First National Bank of Layton in Utah. She wrote a smart, funny, helpful rap to help train her team on the CDD requirements. She's agreed to let us share it here.

In this post, we'll share the CDD training rap, as well as a few other resources about the Customer Due Diligence requirements.

Without further ado, here is the CDD rap you've been waiting for...

The Customer Due Diligence (CDD) Rap

 I’m goin’ to tell you the facts about CDD.

About “beneficial ownership” specifically.

It’s about the human who controls or who owns,

Each entity involved at the outset of a loan.

 

It also applies to a deposit account,

Where the biz is trusting you with money you can count.

A safe deposit box and cash management too,

These and other accounts are where you need to come through.

 

If this law you choose to forget and/or neglect,

You will forever be in the zone of compliance torment.

 

CDD has two prongs that you cannot ignore:

Control and also ownership.  They can be a chore.

Do CIP on the one mister or the miss,

Who governs the business and whose feet all want to kiss.

 

Those who own a quarter or more piece of the pie,

Must too be in your sights as one to identify.

If they in any way have a stake in the game,

You must do CIP or on your head lies the blame.

 

If you fail to adhere to this timely subject,

You will forever be in the zone of compliance torment.

 

When the account is launched you must have rectified,

Who these human souls are and you cannot let it slide.

Get a certificate from one who’s at the meet.

If you forget this step, it is you who takes the heat.

 

Upon this evidence you know you can rely,

Unless you know other facts that make you testify,

That all that is bogus and makes you shout “Say what?”

You must dig deeper until you feel good in your gut.

 

If this law you choose to forget and/or neglect,

You will forever be in the zone of compliance torment.

 

This does not apply to the existing accounts,

Except when something hokey would make you want to pounce.

When material changes in B.O. occur,

Back to this trendy rap song you should plan to refer.

 

Do OFAC and PEP scans for each one on the list,

And doc the file well so you know it won’t be missed.

The sad news I leave you with – and it’s paramount:

You need to repeat this song for every new account.

 

If you fail to adhere to this timely subject,

You will forever be in the zone of compliance torment.

 

[Drop the Mic]

 

by

Anita Garrett, CRCM

SVP, Sr. Compliance Officer

First National Bank of Layton

Spend the time to learn these rhymes, and you will find that your compliance is divine!  You can leave your kind words for Anita in the comments section below, and we will make sure to share it with her.

Ncontracts Viewpoint: We love this rap, and it does a really good job of outlining the key requirements of the Final CDD Rule. If you'd like to learn more about CDD, you may also want to request our Quick Guide to the Fifth Pillar of BSA/AML Compliance. In addition, please know that we offer BSA/AML compliance consulting, and would love to talk about how we can help you improve your program, if that's a priority for you this year.

 

Learn the 5th Pillar of BSA/AML Compliance!

Topics: Banks, News & Updates, Credit Unions, Mortgage Lenders,

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