Q: Are covered financial institutions now required to follow specific procedures to approve changes to AML programs or require Boards of Directors or senior management to approve such changes? Can Federal functional regulators direct financial institutions within their jurisdiction to follow a specific approval process?
A: Covered financial institutions may continue to follow their existing internal procedures for approving AML program changes, including changes that incorporate the Rule’s new program requirements. However, these procedures should be consistent with the requirements and expectations of the institution’s Federal functional regulator.
The above FAQ was included in FinCEN’s 2nd set of CDD FAQs that were released in April 2018. The FAQs are provided to assist financial institution in understanding the scope of the customer due diligence / beneficial ownership rule. The 2018 FAQs may be found here: