CDD Rule Policies, Procedures, Training and Testing

Preparing for compliance with FINCEN's Customer Due Diligence Rule

Navigant Director, Samantha Welch discusses:

  • Revising written policies and procedures and account opening forms to incorporate the CDD Rule’s requirements. 
  • Developing, documenting, and delivering training that explains not only the requirements of the CDD Rule, but how the firm is revising its policies and procedures to ensure compliance with the rule.
  • Conducting user acceptance testing to ensure the information technology systems are ingesting and incorporating all required information into the onboarding process (customer risk profile), recordkeeping, transaction monitoring, suspicious activity investigations, and reporting process.


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