We perform risk assessments all business accounts. Does anyone have a form they use (and would share)to perform an assessment for non-business accounts? All sources I have searched refer to business accounts. I'm a newbie and will take any help I can get!

We do not risk assess non-business accounts. I have written into my risk assessment that personal accounts are considered Low Risk unless other red flags are detected through regular monitoring.

I require all New Accounts to gather Occupation as that helps determine risk.

If you send me a PM with your email address, I will email you a copy of our form.

Only two members of the customers subject to expanded examination overview club are consumer accounts: non resident aliens and politically exposed persons. Your due diligence process should include questions that would identify them at account inception and plug them into your risk weighting system.

Beyond that, an AML risk assessment on consumer customers is of relatively little value. You are looking for money laundering, not penny ante fraud. It would be very difficult to launder money through a consumer account and it's a reasonable assumption that the activity would be abberrant enough to bring it to your attention through the review of daily reports.

The focus of a risk weighting system should be to help you allocate your time intelligently rather than treat all customers as equally capable of laundering money.

This is not the doctrine put forth in the BSA/AML Handbook. It's a position you would have to agree with and be able to defend. (not as)newBSA is apparently able to do that.

Thanks for all your feedback. This forum is a great tool!

I was wondering, if you are not currently risk rating non-business accounts...why do you want to start? Did the examiners suggest it?
Also, for the ones that are risk rating non-business accounts would you share your process? Do you have a point system that determines L-M-H or is it more like all non-business accounts are Low unless they have a high risk occupation or other red flags?

I couldn't agree more Ken. I have found too many people lay down & play dead when an examiner suggests something. I know my program inside & out & my examiners know this. I have a reason for everything I do & everything is clearly stated in my policy.

If you choose not to "Rate" consumer accounts - why not? Be prepared to explain your geography, trends, products & services - all of this should be in your overall risk assessment. When you don't know the answer to that question is when you get into trouble.

• What reports do you have in place to catch suspicious activity?
• What reporting system do you have in place between all Employees & the BSA Dept.
• What is the Mission Statement of your bank? Who do you Market to?(how long your bank has been in the community & the type of customers you attract is something you should be very familiar with)
• If all your consumers are considered low risk, what factors would raise their risk to Medium or High and how would you be notified?

Exactly.

From my policy:
Low Risk

Generally, the customer’s account activity is normal and expected for the type of account and/or profession/business – minimal cash activity. The majority of the Bank’s customers fall under the “Low Risk” category.

• Required Monitoring: All employees who have contact with the customer are responsible for monitoring activity to ensure that transactions are commensurate with normal activity associated with the account. Additionally, various system reports are reviewed and monitored by branch and department personnel. Any unusual activity detected on either an account or report is to be reported to the BSA Officer. The BSA Officer will initiate a risk rating change if warranted.


I then have a long list of Red Flags (found in the BSA Manual) & Other Risk Factors that we made up based on the classic Geography, Products, Transactional Activity ... yada yada

We have a similar policy for risk rating new accounts at opening but it is very simple because we try to use the "KISS" (keep it simple stupid) method as much as possible.
When opening a new account if the individual meets at least 4 of these requirements they are coded as high risk:
•Apartment Address or home and business address are the same, or foreign address.
•Over $5,000 in cash opening deposit.
•Short-term employment (less than two (2) years).
•Short time at current address (less than two (2) years).
•Out of state Driver’s License or ID
•Work or home not in the vicinity of the branch.
•Existing customer who is less than one year, and has record of repeated overdrafts.
•Non-U.S. person.
•Unemployed

After 90 days if there has been no negative activity the officer can request a review be done by BSA and if we determine the activity is consistent with a consumer and not suspicious, we will remove the high risk code.