I have been diligently working on updating our BSA/AML Policy and note, as an FDIC regulated bank, we must have procedures in place to monitor high-risk businesses. The OCC provides guidance on what types of businesses are high risk and to be monitored, but I didn't see anything from the FDIC. Is it ok to use the OCC's list or will we find trouble by singling out those types of businesses for monitoring?
Thanks for your thoughts!