Forum Replies Created
-
Posts
-
WE are also verifying that the beneficial owners are entered into the appropriate fields on our core system to ensure that the names are compared to the OFAC list on a nightly basis.
With respect to monitoring, our BSA Department will be obtaining a list of new deposit accounts and new/renewed loans for legal entity customers each month and selecting a sampling of accounts to review to ensure the CBO was obtained and that the form is complete (no omissions of required data) and that it was reviewed by the appropriate persons.
We already have monitoring procedures for CDD.
Unless your loans “automatically” renew, I do not believe the relief applies. Most loan renewals require a credit review before the loan is renewed. I’ve read several articles on this and that appears to be the consensus. This is yet another example of how FinCEN is out of touch with how things are done. It never hurts to contact your regulator for their interpretation though.
