Non-Federally Regulated Banks Are Target of Proposed FinCEN RulesLast month the U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) proposed new rules which would require non-federally regulated banks to implement Customer Identification Program (CIP) requirements related to the collection and verification of customer information. Financial institutions have until October 24, 2016, to comment on the proposed rule, which, if adopted, is estimated to

The “Fifth Pillar” of AML/BSA Compliance FinCEN Issues Final Rule for New Customer Due Diligence Requirements under the Bank Secrecy ActFor years, financial institutions have operated under the maxim that an effective anti-money laundering and Bank Secrecy Act compliance program (collectively “AML”) rests upon four pillars: (1) written policies and procedures; (2) a designated AML compliance officer; (3) independent testing of the institution’s AML program; and (4) implementation of an adequate employee training program. Now