When considering a new account, do you consider lawyers, doctor practices, and other professional services as potential high risk customers and perform enhanced due diligence? I am having a lot of push-back that these types of professionals are not higher risk and therefore should not be subject to enhanced due diligence.

Okay first..I have to ask...does YHWB stand for Yellow Hammer Wanna Be?

Yes, these are high-risk in our shop.

You may want to go back and review the Expanded Examination Overview and Procedures of the FFIEC BSA/AML Examination Manual. There is a section on Professional Service Providers (page 277) that should give you some information on risk factors that you can share with the bank.

I understand the manual! I am interested in market practices.

ACtually, I believe Halito has given you the best ammo you could possibly use to show these folks why these professional individuals are grouped as such...what the industry/market practice is or isn't isn't going to make or break you come exam time.