Thread Options
#2245276 - 11/09/20 03:58 PM Ongoing High Risk Customer Review Data
SmallBank3 Offline
Member
Joined: Nov 2019
Posts: 55
What are the main data points you are looking at when you are doing monthly high risk customer reviews? We (and when I say we I mean me as I'm the only compliance person for a 400M bank) are currently doing manual reviews with about 30 customers listed as high risk and another . I'm trying to boil it down to what is most helpful and effective for the time I have. The spreadsheet from the previous compliance officer is … huge. I'm trying to boil it down to what is truly most useful and would appreciate any insights on your experience and thoughts. Thanks!

Return to Top
BSA/AML/CIP/OFAC Forum
#2245283 - 11/09/20 04:45 PM Re: Ongoing High Risk Customer Review Data SmallBank3
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 77,548
Galveston, TX
Monthly reviews? - these must really be high risk customers. Monthly reviews of extremely high risk accounts would be customized based on the risks presented by the individual customer. I would not think that you would have a cookie cutter review for high risk customers.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#2245310 - 11/09/20 07:29 PM Re: Ongoing High Risk Customer Review Data SmallBank3
praBSA Offline
Gold Star
Joined: Aug 2018
Posts: 281
I agree. Monthly reviews seems excessive unless these are extremely high-risk such as MSBs or something. I am now at my second bank as BSA/AML Officer under 500m in assets. We conduct high-risk reviews annually. I've designed my own review process over the years. Develop your own process and stick with it. Make sure to compare data/activity over that time period, year over year/quarter over quarter/etc. When I came here about 6 months ago, I re-wrote our risk-assessment, changed the reviews from quarterly to yearly, wrote new policies and procedures. Make the program your own. You don't need to follow what the previous CO used, it's your program now, make it yours.

Return to Top
#2247904 - 01/20/21 09:46 PM Re: Ongoing High Risk Customer Review Data SmallBank3
TaraTLR Offline
100 Club
Joined: May 2013
Posts: 128
We are looking at updating our High Risk Procedures at my Bank as well. I am trying to get some opinions from other Banks if they add all of their new accounts to the high risk monitoring logs or if they use the risk category based approach of low, moderate and high based on the CDD procedures.

If you are adding all new accounts to the high risk log, how long are you keeping them on the log?

Return to Top
#2247906 - 01/20/21 10:04 PM Re: Ongoing High Risk Customer Review Data SmallBank3
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 77,548
Galveston, TX
You would have to be a small bank with a lot of staff to add all new accounts to your high risk customer list for periodic EDD reviews.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#2247909 - 01/20/21 11:32 PM Re: Ongoing High Risk Customer Review Data SmallBank3
TaraTLR Offline
100 Club
Joined: May 2013
Posts: 128
We are a small bank. We add our new accounts to a 90 day high risk monitoring log, that we maintain manually. I am just trying to figure out if this is what other banks are doing as well. I don't really see that it is necessary to monitor all new accounts, especially when they are just plain consumer deposit accounts. Do you have any alternate recommendations?

Return to Top
#2247911 - 01/20/21 11:43 PM Re: Ongoing High Risk Customer Review Data SmallBank3
ACBbank Offline
Power Poster
ACBbank
Joined: Jul 2006
Posts: 3,990
New York City
Monthly is a bit much. Assuming that you are using a three scale system I've generally seen high risk at six months, medium at twelve months, and low at twenty-four months unless a triggering event warrants a review off schedule.
_________________________
"100 victories in 100 battles isnt the most skillful. Subduing the other's military w/o battle is the most skillful." Sun-Tzu

Return to Top
#2247931 - 01/21/21 03:57 PM Re: Ongoing High Risk Customer Review Data SmallBank3
ColoradoAML Offline
100 Club
Joined: Mar 2018
Posts: 240
Since FinCEN only expects you to review for confirmed suspicious activity every 90 days, I agree that reviewing high risk customers monthly may be excessive. If these reviews aren't resulting in SAR investigations, I might argue that that alone is evidence that you can review them less frequently. We currently review high risk customers annually.

TaraTLR, similarly, if you're not getting anything out of the reviews, maybe you don't need to be doing them. I'd recommend starting with the exam manual and considering doing reviews only on the types of customers FinCEN identifies as HR.

Return to Top
#2248018 - 01/22/21 04:31 PM Re: Ongoing High Risk Customer Review Data SmallBank3
StacyLitkeGCV Offline
New Poster
Joined: Nov 2020
Posts: 9
Certainly agree with others that every 90days is plenty, no need to do monthly.

The data points will depend on the reason they're high risk, for example, if these are MRBs you're going to want to make sure they're still licensed, that the transaction verification shows legal sales, there's been no negative press and so on.

But for the most part you'd want to look at account activity for anomalies that need understanding or explanation. Transactions that are not "normal and expected" for the business.

Return to Top
#2248090 - 01/25/21 04:18 PM Re: Ongoing High Risk Customer Review Data SmallBank3
JennKK2 Offline
100 Club
Joined: Nov 2006
Posts: 212
-
As the BSAO I conduct HR reviews quarterly.
_________________________
plan your Work and Work your Plan

Return to Top

Moderator:  Andy_Z