New to the forum. New to my position. I came from a large bank to a small/local community bank.
Here, the entire BSA/AML process is entirely manual from CTR/SAR/Transaction Monitoring/Risk rating customers/Reviewing CIP docs/tracking/etc.
Here is my question:
Right now, as the entire process is manual, front-line employees have been instructed to forward me all Beneficial Ownership forms. I am tracking them all on a spreadsheet. Up until this point, BO Cert forms were only being collected for new customers with new accounts, not existing customers. I immediately fixed that and have instructed that all new accounts should have BO Forms completed as well. Is this information supposed to be verified at every account opening regardless of a week later vs a year later? Can the bank assume the risk and only verify it yearly for example? Or does the rule say we need to verify/complete a form at every opening? If so, can you point me to the guidance indicating that to take to my CRO?
There is clearly a lot of work to do with this process being so manual and behind in technology. I was brought onboard to automate the process as quickly as possible to relieve some of this burden. I just want to confirm what is expected in terms of re-cert requirements.
I appreciate all the help.