Revised Policy Templates for June 2016
These products were revised in response to FinCEN’s final rule entitled “Customer Due Diligence Requirements for Financial Institutions” which was published in the Federal Register on 05/11/16 that clarifies and strengthens customer due diligence requirements for banks, brokers or dealers in securities, mutual funds, and futures commission merchants and introducing brokers in commodities. The rules contain explicit customer due diligence requirements and include a new requirement to identify and verify the identity of beneficial owners of legal entity customers (beneficial ownership), subject to certain exclusions and exemptions.
As a reminder, the complete contents of the Customer Identification Program Policy Template are included within the Bank Secrecy Act Policy Template – Comprehensive Version as Topic 7.
These products were revised in response to OCC’s Bulletin 2016-9 that announced a revised “Oil and Gas Exploration and Production Lending” booklet which replaces the “Oil and Gas Production Lending” booklet issued in April 2014. The new booklet provides updated guidance on the risks inherent in lending to upstream oil and gas exploration and production companies and provides guidance on prudent risk management of this lending activity.