Randy and I put your auditor through the ringer pretty well for the CIP question. Before I do so again, I would point out that anticipated activity should fall under CDD, not EDD. Although CDD does not specifically state anticipated activity like EDD, the CDD section states, "The objective of CDD should be to enable the bank to predict with relative certainty the types of transactions in which a customer is likely to engage."
For business accounts, obtaining anticipated activity enables you to try and understand the normal and expected activity for the account and also assists in identifying higher risk customers. If I tell you at account opening that I am planning to sent on average $100k a month in international wire transfers or deposit $100k in cash, you may want to ask me some additional questions.
Anticipated activity for most consumer accounts will be the same so generally the questions we ask at account opening for consumer accounts may be less intense than a business. The list of documents in the enhanced due diligence section of the exam manual are items that we would ask of those higher risk customers that we identify, not all customers. The exam manual is pretty clear on this..."The bank may determine that a customer poses a higher risk because of the customerâ€™s business activity, ownership structure, anticipated or actual volume and types of transactions, including those transactions involving higher-risk jurisdictions."
Am I asking all my customers for financial statements or performing site visits? No
Am I obtaining some type of benchmark statement of anticipated activity for all businesses so I can understand the "normal and expected activity, identify MSBs, privately owned ATMs, etc.?" Yes.
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