We are working on changing our Enhanced Due Diligence for high risk customers and have some questions. According to the FFIEC, accountants, attorneys and doctors can be included in high risk customers. With EDD you are supposed to get a list of major customers and suppliers. How can these professional provide that without violating their confidentiality agreement with their clients? Cash intensive businesses like a convenience store, restaurant or retail store are also considered high risk. Do you really need a list of their major customers? Also, if they can be high risk why is it you can exempt them from CTR reporting?

We don't do EDD unless we determine the client is High Risk. & depending on the situation, you wouldn't get a specific list of a doctor's clients .... but maybe you understand his customer base. Like he only deals with elderly individuals, or he's a family practice, or he's a plastic surgeon for the stars. Knowing that information should help you identify what type of activity you should be seeing.

Again with cash intensive customers. A Gas Station for instance, they should deal with state lotto, beverage distributors and gasoline. Who are the vendors they use & generally what clientele? (Are they open 24/7? Are they on a major freeway? Are they in a small town of 100 people and still accept checks?)

Just because someone may be initially classified higher risk - doesn't mean they stay that way. You could have enough mitigating factors and KYC documented to lower their risk or Exempt them from CTRs.

For example: I bank McDonalds. (example only). We know McDonalds is cash intensive ... but they're supposed to be .... so I feel comfortable exempting them from CTRs.

We are taking recommendations from the FDIC and trying to implement. As we work through implementation, we realize that what the FDIC said isn't practical.

Ditto what WW said. Using a doctor as a hypothetical example: we bank 2 walk in clinics, they can have higher levels of cash activity as their clientele may be "unbanked" type people. When you look at activity and question the client, the smaller clinic has double or triple the amount of cash, in looking at the activity, it's not reasonable for the smaller clinic to have so much cash. You might risk them higher and perform extra due diligence and/or monitoring but you rate the other clinic low as their activity is normal/expected.

Imagine that! No, really. We need to be able to bring these rouge examiners and field offices to the table with FinCEN and hold all of these "recommendations" to a harsh light. To me it is RIDICULOUS that banks are WASTING time, energy and resources chasing after errant butterflies just to satisfy an examiner rather than focusing on finding truly suspicious or criminal transactions.

It's like having as a back seat driver someone who has never actually, you know, driven a car!

Amen! (if I'm allowed to say that in public anymore.)