Would you consider a doctor's office a 'PSP' as far as what the FFIEC considers a 'High Risk' business.??

No. As the FFIEC manual states "a professional service provider acts as an intermediary between its client and the bank".
So, lawyers, accountants, investment brokers and others may be applicable.

However, practicing medicine is one of those specified activities for which a CTR exemption cannot be granted.

Thanks Doug. I've gone back and forth on this particular business line. I was thinking along the lines of how we risk rate each individual account (Low, Moderate, High), not CTR Exemptions.

I found this in the FFIEC Manual : http://www.ffiec.gov/bsa_aml_infobase/pages_manual/olm_005.htm


Under Customer and Entites topic heading, the last line reads "Professional service providers (e.g., attorneys, accountants, doctors, or real estate brokers)."

Just wanted to see if anyone else out there is classifying a doctor as 'High Risk'..

This topic came up at Top Gun last March. What drives the PSP designation is if the customer is handling funds that does not belong to them. (For example a lawyer has a LFTA where it holds client funds from settlements, an accountant may receive investment funds, an insurance broker may take premium payments.)

Generally a doctor is not engaged in this activity. They perform services, the patient or insurance company pays them. Some doctors have set up their own finance companies to establish payment plans for patients that cannot afford to pay in a lump sum. From a money laundering standpoint, it is possible that a doctor could create false invoices to commit insurance fraud or to accept patient payments for services they have not actually provided to aid their "patients" in getting funds into the banking system.

Does this make a doctor high risk? No. As with all clients, you should develop an understanding of the size of the practice, anticipated activity, etc. and review activity that seem inconsistent with a doctor's office.

Brian, as always, has laid it out very succinctly.

Would a rental agent who opens security deposit escrow accounts be considered a PSP?

'K