Would anyone be willing to share their Customer Due Diligence program? We currently do not have any type of AML software. Another thing we do not do is collect additional information at account opening (other than normal CIP information). So we basically have a manual process that we implemented last year and are trying to tweak. It would be very helpful if we could take a look at what other banks like us have done. Any help would be great. We currently try to identify certain customers (cash intensive, SAR's, NRA's, MSB's) and risk rate (with matrix) them to see if further due diligence is needed. It would be nice to have a better system, but for now this is what management has decided to use.

I've shared mine with several BOLers...send me your email and I'd be happy to share it with you too