Our examiner has stated that we should be doing a deeper surveillance review of "higher risk" customers who crop up in our suspicious activity review process. Do you approach these customers in the same way or do you do something different in regards to suspicious activity monitoring of your higher risk customers?

We complete EDD reviews on them but they run against the same set of rules within our suspicious activity module as "non-higher risk" customers. I also do not think we can segregate them out to run against a separate set of rules.

Thanks for any input!

It sounds like your examiners may not be satisfied with the quality of your EDD reviews. Perhaps the reviews are not as comprehensive as they would like. This seems to be a popular criticism these days.

Our high risk customers are also subjected to the same alerts as all other customers.

When you aren't clear on advice provided by an examiner, it is best to keep asking questions until you are clear. Ask them to be specific about what they want you to do.

Quarterly we scrub our High Risk listed customers for this:
and "this" is a result of an exam a few years ago.
Name:
TIN#:
Account #'s
Review completed by:
Date range of review:
Risk listing date:

1. Review quarterly transactions
2. SAR's files? yes/no
3. CTR's filed? yes/no
4. suspected kiting? yes/no
5. Wires? yes/no
6. Loans? yes/no
7. now selling prepaid access cards? yes/no
8. ATMs owned? yes/no
Followed by a paragraph discussion about the account activity, finishing with a discussion about how to proceed, keep them on/off?. Reviewed by more than one person.
We are a small bank.