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Music I'm Gloria Leduc here on the CU compliance connection by league info site bringing you a brief overview of FinCEN's new rule for customer or member due diligence requirements for financial institutions compliance with these new rules is required on May 11th of this year and with multiple frequently asked questions issued by fencin we thought it would be a good idea to pra high-level summary and overview back in 2022 FinCEN or the Financial Crimes enforcement Network issued new rules under the Bank Secrecy Act or BSA to clarify and strengthen customer due diligence requirements for financial institutions these new rules created a new requirement for credit unions to identify and verify the identity of beneficial owners of legal entity customers or members there were also changes to anti money laundering or AML program requirements which will require credit unions to implement and maintain appropriate risk-based procedures for conducting ongoing member due diligence for all members which includes first understanding the nature and purpose of the customer or member relationship and to conducting ongoing monitoring to identify and report suspicious transactions and on a risk basis to maintain an update member or customer information therefore in order to comply with new rules which is required on or before May 11th credit unions need to make sure their member or customer due diligence program is updated to include the requirement to identify and verify the beneficial owners of legal entities and update their overall AML program to include risk-based procedures for conducting that ongoing due diligence for all members so how will these changes impact the credit unions existing processes first after May 11th when legal entity members come in to open a new account the credit union will need to obtain certain information from them in order to identify those beneficial owners now the credit union can obtain that required information by either having the legal entity member fill out the certification form that is included within Appendix A of the regulation or through another method if the credit union is using an alternative method they need to ensure they're capturing the same data at a minimum that's included in the certification form in Appendix A additionally if using an alternative method the credit union will still need to obtain certification from the individual who's providing the information of its accuracy for purposes of our review today we will consistently refer to the use of the certification form but viewers should know as we just explained that doesn't necessarily mean they have to use this form the alternative method we just described is also permissible this information can be obtained from the individual seeking to open a new account at the credit union on behalf of the legal entity member so that may be an authorized signer for those credit unions that plan to use a certification form within Appendix A it's available on FinCEN's website in a fillable PDF or Word format in addition to.