FinCen Final CDD Rule June 15, 2018

Moderator: Snežana Gebauer Snežana Gebauer is executive managing director and head of the Investigations and Disputes practice of K2 Intelligence. She is based in New York. Snežana oversees high-profile corporate investigations focused on corruption and various types of fraud, often of cross-border character. She advises senior executives and legal counsels around the world on a variety of risk and compliance issues, transactional due diligence and provides investigative and risk management support in business disputes. Her clients include , financial institutions, corporations, governments and law firms. Over the course of her career she has lived and worked in New York, London, Washington, D.C., and São Paulo, and served clients in the United States, Europe, Asia, the Middle East and Latin America. Snežana received her M.B.A. from George Washington University and her B.A. from Drake University. She also attended The American Institute on Political and Economic Systems at Georgetown University. She is fluent in five languages.

Panelist: Edwin Rivas Edwin Rivas is the Chief Compliance Officer of Bank of India, responsible for overseeing the regulatory compliance governance for the US Centre, comprised of New York, San Francisco and Cayman Island’s operations for both retail and wholesale banking business. He is also primarily responsible for managing relationships with key regulators such as the Federal Deposit Insurance Corporation (FDIC), Federal Reserve Bank (FRB), the New York State Department of Financial Services (NYDFS), the California Department of Business Oversight (CDBO) and the Cayman Island Monetary Authority. Mr. Rivas is also a member of the US Centre’s executive management team. Mr. Rivas is a Certified Compliance Regulatory Professional (CCRP),  Certified Regulatory Compliance Manager (CRCM), ), a Certified Anti-Money Laundering Specialist (CAMS) an Anti-Money Laundering Professional (AMLP), Certified Financial Services Auditor (CFSA) and a Certified Risk Management Assurance (CRMA); and a member of the Institute of Internal Auditors, the Institute of Certified Bankers, the Association of Certified Anti-Money Laundering Specialist, the BAI (Bank Administration Institute) and a Board member of the AIBACP.

Panelist: Mildred Harper Mildred Harper serves as Senior Vice President, Chief Compliance Officer of the New York Branch of China Construction Bank, since January 2014. In this role, she is responsible for overseeing and implementing the Branch’s BSA/AML, OFAC and Regulatory Compliance Programs, and developing Branch policies designed to ensure compliance with U.S. regulations. In addition, to co-chairing the Risk Management, Internal Control and Compliance Committee, she advises Senior Management and the Bank’s Head Office, regarding U.S. regulatory requirements. Prior to joining China Construction Bank – New York Branch, served as Regional Compliance Officer for Banco do Brasil’s U.S. Operations, responsible for developing and implementing U.S. compliance policies and initiatives. Ms. Harper is a Certified Regulatory Compliance Manager (CRCM), a Certified Anti-Money Laundering Specialist (CAMS) and is a current Certified Compliance and Regulatory Professional (CCRP) candidate.

The Final CDD Rule in a Nutshell The Final CDD rule imposes a new requirement for CFIs to identify and verify the identity of beneficial owners of legal entity customers the identity of the individuals who ultimately own 25% or more of equity interest in the legal entity, and the identity of an individual with significant responsibility to control, manage or direct the legal entity or perform similar functions. Covered Financial Institutions (CFIs): federally regulated banks and federally insured credit unions, mutual funds, brokers or dealers in securities, futures commission merchants, and introducing brokers in commodities.

Areas of Ambiguity Existing customers, but new accounts, new products, rollovers or renewals Exempted legal entities customers Legal entity customers with complex corporate structures Verification of beneficial ownership Enhanced due diligence Beneficial ownership threshold Beneficial ownership of trusts with multiple trustees