Our institution has recently begun to offer Cash Management services to our business customers. Just wondering of any banks out there that currently provide Cash Management services; do you treat these customers with any higher risk or monitoring due to the elevated risk of wire transfers or ACH's that could go undetected to possible terrorist or money laundering activities? I'm just not too sure what to do with the customer monitoring that will grow from this product. We have about twenty customers right from the get-go who are beginning to use Cash Management services. Thanks for any insight! I greatly appreciate it!

When you say 'cash management', are you referring to payment processing or investing / holding in custody the proprietary assets of a company?

We have Cash Management customers doing both wires and originating ACH. The examiners want to see it addressed in your risk assessment. Our AML software pulls in both wire activity and ACH activity. We do a credit evaluation and Enhanced due diligence on the customer. The examiners have been satisfied with what we have done so far.