We are at the stage of risk rating the entire customer base and then implementing procedures for new account opening and ongoing. we are rating everyone LOW then working from there adjusting as need be going forward. My question is, Did everyone have a similar approach? I am open to ideas. Thanks

We're going to take the approach where we define what types of activities we consider high risk and then figure out which customers conduct these types of activities (MSB type services). That will determine who is considered high risk. You state you're rating everyone low and adjusting from there. What determines who gets a higher risk than low?

Our CSRs are risk rating existing customers as they come in to establish new accounts. Most have been coming up as low risk, but, depending on the nature of their activity they may come up as mod.

we are developing the criteria based on transaction habits, CTR filings, SAR filings etc. evolving as we speak

We data mined existing customers to determine those that had risk factors warranting formal risk rating (such as large cash transactions, pre-determined NAICS codes, foreign wires, criminal subpoenas, etc.). All others will be considered low unless they hit one of our BSA or high risk radars. All new customers will be rated as new relationships are established.

The Risk Rating Customers tool may help.