Written by Don Lee FINCEN published its final long awaited ‘Customer Due Diligence Rule‘ (CDD) for covered financial institutions on May 11, 2016. FINCEN states there are four elements of the CDD that must be explicit in AML procedures. These include: (1) customer identification and verification; (2) beneficial ownership identification and...
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Written by Don Lee In the recent Technology Tools for Today conference hosted by Investment News on November 2nd in Florida, Big Data was once again a topic among the financial community. The general consensus among the broker dealers present was “the additional uses of Big Data is likely to spur more attention from government and industry...
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Written by Don Lee The first question regulators often ask during an initial examination interview is ‘do you have a risk based program?’ Most compliance officers will jump the gun and reply ‘Sure we do!’. The follow up question however stumps compliance officers when the regulators ask ‘How do you monitor and maintain your...
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