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#1949912 - 08/06/14 09:07 PM NBFI / MSB / High Risk Customer Site Visit Form
charlied Offline
Member
Joined: Oct 2009
Posts: 94
TN
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.

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#1950047 - 08/07/14 02:13 PM Re: NBFI / MSB / High Risk Customer Site Visit Form charlied
MagicCity Offline

Power Poster
MagicCity
Joined: Apr 2003
Posts: 3,003
Fort Lauderdale, Florida
Your list sounds pretty good if all you are doing is establishing if they are an MSB.
There would be other questions once you establish exactly what they do.

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#1950068 - 08/07/14 02:28 PM Re: NBFI / MSB / High Risk Customer Site Visit Form charlied
charlied Offline
Member
Joined: Oct 2009
Posts: 94
TN
Thanks! What other questions might you suggest?

The specific situation I'm dealing with is a convenience store that I recently noticed was getting regular ACH debits from Western Union. So, I went on WU's site and found them listed as an agent. The only product listed for them is money orders, but this contradicted what they said at account opening (years ago, before my time). So, while I'm not saying that they intentionally misled the bank back then, I can't help but wonder what other products/services they may have gotten into that we are not aware of. Past that, I'd like to have a standard form to use whenever I feel that a customer may have started offering a product/service that significantly affects their risk rating such as NBFI/MSB activity.

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#1950101 - 08/07/14 02:52 PM Re: NBFI / MSB / High Risk Customer Site Visit Form charlied
MagicCity Offline

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MagicCity
Joined: Apr 2003
Posts: 3,003
Fort Lauderdale, Florida
With a convenience store I would do a site visit and ensure that I understand all the services/parameters that generate cash; i.e. lotto, hot food, size of store, volumes of merchandise, phone cards etc.
I compare customers in the same industry, so if you have one convenience store depositing substantially more cash than other, you want to be able to explain why.
If their only connection to an MSB is being a WU agent, I would consider them a Medium risk.

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#1950261 - 08/07/14 04:56 PM Re: NBFI / MSB / High Risk Customer Site Visit Form charlied
Sunshine Lady Offline
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Sunshine Lady
Joined: Apr 2014
Posts: 588
The other thing that comes to mind for me based on your concerns about their activity is that if the branch manager has time, have them sit and watch to see what their customer traffic looks like or do a drive by to see how many cars are there especially during what they would consider their busy hours.
_________________________
Define Success on your own terms, achieve it by your own rules, and build a life you are proud of. Anne Sweeney

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#1950500 - 08/07/14 08:02 PM Re: NBFI / MSB / High Risk Customer Site Visit Form charlied
charlied Offline
Member
Joined: Oct 2009
Posts: 94
TN
"...do a drive by..." Well ummmm, while I am a bit suspicious of their activity I don't think that violence is the answer. smile


But thanks so much for the input so far, everyone! Feel free to keep adding to it if something else occurs to you.

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#1950520 - 08/07/14 08:19 PM Re: NBFI / MSB / High Risk Customer Site Visit Form charlied
kw004h Offline
100 Club
Joined: Nov 2009
Posts: 219
Chicagoland, IL
Also, although it's becoming rarer and rarer these days, with a convenience store that is also a gas station, note whether or not the pumps accept credit cards. Some stations still have not installed them into their machines, or have gone back to the prepay via cash method because of too many drive-offs.

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#1950533 - 08/07/14 08:28 PM Re: NBFI / MSB / High Risk Customer Site Visit Form charlied
Sunshine Lady Offline
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Sunshine Lady
Joined: Apr 2014
Posts: 588
I had to laugh myself at my "drive by" comment.
_________________________
Define Success on your own terms, achieve it by your own rules, and build a life you are proud of. Anne Sweeney

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#1950830 - 08/08/14 04:03 PM Re: NBFI / MSB / High Risk Customer Site Visit Form charlied
BSA Smitten Offline
Junior Member
Joined: Jul 2013
Posts: 41
Great Lakes
***Require a copy of their AML Program.

I have a few docs I can send you, if you PM me your email.
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"Water your own grass and keep it greener on your side" - Me

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