I’m putting together a ‘due diligence’ questionnaire for our sales staff to use when opening new deposit accounts, especially for commercial customers. We are trying to establish benchmark criteria for BSA/AML monitoring of these accounts for suspicious activity. [Plus maybe probe for cross-selling opportunities, and do some risk projection for pricing purposes]. I need some help coming up with suitable questions, especially related to SA monitoring. Here’s a start. Can anyone add more?

Currency deposits: typical daily/ weekly amounts
Currency/coin needs: daily, weekly amounts
Domestic wire transfers: anticipated monthly number and dollar volume as originator/ receiver.
International wire transfers: Anticipated monthly number and dollar volume as originator/ receiver.
ACH credit transactions: Daily/monthly number, dollar volume.
ACH debit transactions: Daily/monthly number, dollar volume.
ACH: RCK activity? Describe.
ACH: any transactions involving the Internet, including WEB entries? Describe.

Or, if anyone has an entire questionnaire they’d be willing to share, or at least share the part with their benchmarking questions, I’d be grateful. Please PM me. Thanks! I'll offer to share the final questionnaire with any contributing posters.

>Type of business
>Is this a cash business
>Have an indicator if the type of business is on the OCC 'high risk list' or otherwise is a cash business that could need additional monitoring
>Number of checks written in a normal month
>Balance normally maintained in checking account
>Will there be a separate payroll account? If yes, # of employees, frequency of payroll, balance maintained

This may be a little much, but when someone asks me how can I document what I know about a customer, in addition to the above, I think of the following:
> sources of initial funding (if opening deposit accounts, where did the money come from?)
> if a business account, how long they have been in business?
> who are the principals of the business, and what does the rep know about them; i.e. their experience, backgorund, knowledge, etc.
> what are the related parties (related interests); i.e. sometimes you open accounts under different names or sub-entitites
> what/where do they get their major source of income? (i.e. is it internet sales, local sales, international sales)
> has the sales rep visited the site, visited their website, known them as a prior bank or situation, reviewed their financial statements, reviewed their credit report or D & B report, references?