The Directors Education Series: BSA, AML & CDD: Beneficial Ownership Rules

FinCEN's final rule enhancing each bank's Customer Due Diligence (CDD) program required under the Bank Secrecy Act (BSA) was published on May 11, 2016 and applies to MANY types of financial entities. Financial institutions are required to identify and verify the identity of the beneficial owners of each of their legal entity customers. Beneficial ownership must be identified with each new account or other compliance triggers using a Two-Pronged Test covering the following important elements about your nonpersonal customers:

  • Ownership - Identify up to 4 individuals with 25% or more direct or indirect ownership in the entity's equity
  • Control - Identification of one individual with significant responsibility to control, manage, or direct a legal entity

This overview will assist you in determining which entities are covered by the new rule and other important aspects of CDD that will be evaluated in your next BSA examination including:

  • BSA's Four Pillars + CDD/BO
  • Key BSA/AML Components
  • Money Laundering
  • Customer Identification Program
    • Customer Verification
    • Definition
    • Accounts
  • Customer Due Diligence
  • Enhanced Due Diligence
  • Beneficial Ownership
  • Legal Entity Customer
  • Exclusions from Legal Entity Customer
  • Limited Beneficial Ownership CDD Entities

Subscribe to The Directors Education Series and provide your leaders with the guidance and tools needed to navigate the complexities of today's banking environment.

training features:

  • Includes Audio, Video and Powerpoint.
  • PDF Handouts
  • Discussion Questions
  • 20-25 minutes in length (Perfect to show at your monthly board meeting!)
This program is a breakout session from the Directors Education Series, which is a subscription based Library containing over 50 trainings specifically for your Board of Directors. For more information on the Directors Education Series click on or go to You can email questions to or talk with a representative by calling 1-800-831-0678.

Who Should Attend?

This program is recommended for your Executive staff including every member on your Board of Directors.

We are loving the program for our Directors. Training has now become a more regular event and the format and timing of the training is just right for the BOD. They have found the information very helpful in understanding their roles as directors.” — Maureen Daehn, CFO, Maple Bank

After 42 years in Banking and now a Director, the series enables me to continue my knowledge in this ever changing industry! You're never too old to learn, and being a Director it's our responsibility to continue to learn for the good of our organizations.” — Gerald Schmidt, Board Member, Stephenson National Bank and Trust