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#1250949 - 09/16/09 03:07 PM High Risk Customers
Pisces Offline
Member
Joined: Nov 2006
Posts: 67
Texas
Are we required to present a list of high risk customers to our Board of Directors?

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BSA/AML/CIP/OFAC Forum
#1251181 - 09/16/09 04:55 PM Re: High Risk Customers Pisces
80's Lady Offline
Gold Star
Joined: Apr 2007
Posts: 295
I know of no such requirement. Keep in mind if you present a "list" that contains actual names it could be reflected in the Board Minutes, which are subject to discovery through a subpoena. I do list a general description of the amount of high risk customers we bank in my BSA Risk Assessment (something like "the bank has a small number of accounts identified as high risk"...). Our Risk Assessment is presented to the Board annually or as updated for their information purposes.
_________________________
I use to think I was a smart cookie before I started working in Compliance. Now, I have mastered the art of the blank stare!

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#1251511 - 09/16/09 08:09 PM Re: High Risk Customers 80's Lady
nemsi Offline
Gold Star
Joined: Nov 2005
Posts: 383
ditto to 80's lady comments.

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