It is always a good time to talk about customer identification procedures (CIP) and customer due diligence (CDD), because at some point everyone has struggled to navigate the rules and decipher what the requirements are for credit unions. Recently, the Financial Crimes Enforcement Network (FinCEN) issued new FAQs to provide responses to three common questions regarding customer due diligence (CDD) requirements. The FAQs cover CDD risk-based procedures, the customer’s risk profile and on-going monitoring. In addition, in April 2020, FinCEN issued FAQs related to the collection of information for Paycheck Protection Program (PPP) applicants. So, what a perfect time for a quick refresher!
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