Good Afternoon,
I am trying to create a checklist to give a branch manager to take with them to perform a site visit on a high risk customer whose activity I believe doesn't match their stated activity based on their original answers to our due diligence questions. Currently, the list consists of:
1. Do you cash checks or give cash back on checks for customers? Over $1,000 for any one customer in a single day?
2. Do you sell (or redeem for cash) money orders or traveler's checks? Over $1,000 for any one customer in a single day?
3. Do you sell pre-paid access devices? Over $1,000 for any one customer in a single day?
4. Do you exchange currency for customers? Over $1,000 for any one customer in a single day?
5. Do you transmit/wire money for customers?
6. Do you engage in or facilitate internet gambling?
7. Do you sell lottery tickets?
8. Do you have an ATM? If so, who owns it/is it branded?
9. Are you an agent for an MSB such as Western Union?
Any ideas about what other items I may want to include in the review? All help is appreciated.