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Funds Society Interview with Carlos Gonzalez-Stawinski: FinCen Files: Regulatory Implications
TRANSLATION
1. First, one may wonder about the scope of the leaked documents. Reports of suspicious activity sent to U.S. authorities between 2000 and 2017 are reported. It is a fairly long period in which regulatory changes continued to occur in the United States and around the world. So, what kind of documents are we talking about?
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Regulation Best Interest: What Now? Part two
During our last column we wrote about Regulation Best Interest (Reg. BI) and what should be included as part of your post-implementation analysis. Then, we recommended to follow a three-step process: Calibrate, Adjust and Learn. Now, we would like to focus the attention in an area of Reg. BI that is getting regulatory attention and that we believe will continue to be subject of much discussion: The Client Relationship Summary or Form CRS. Form CRS1 is a one of the two (2) disclosure requirements created under Reg. BI’s Disclosure Obligation. The document is designed to provide, in a simple, plain, and succinct…
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Know Your Customer, Politically Exposed Person and Customer Due Diligence
On August 21, 2020 the main regulatory banking agencies from the United States issued a joint statement (Joint Statement) clarifying the obligations of banks in the United States regarding customer due diligence (CDD) and enhanced due diligence (EDD) processes, surrounding Politically Exposed Persons (PEP)1.
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