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#99137 - 07/21/03 06:34 PM OCC High Risk Accounts for BSA
Kansayaku Offline
Diamond Poster
Joined: Jan 2003
Posts: 1,454
metsuretsu
I have a S&S exam coming up in another week and need your help. They are asking for "A list of products, services, customers, and geographies with high risk for money laundering." I know that the OCC Consumer Compliance BSA Handbook has a good listing of High-Risk Areas, etc.

My question is, how do I go about relating this information to my account database? Do I consider everything that falls into one of the listed categories as high-risk? That would be a large number of accounts and several of the impacted accounts do not seem to be high-risk. Should I only consider this to be a basic guideline from which I should begin my designations?

All help is deeply appreciated. Thanks in advance for your comments and the time required to make them.
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#99138 - 07/21/03 06:41 PM Re: OCC High Risk Accounts for BSA
Lestie G Offline

Power Poster
Joined: May 2002
Posts: 3,608
Near the Land of Enchantment
This is a tough one! We started with the OCC's list, identifying accounts in those categories. Then, we added some accounts owned by foreign nationals (a big category for us). Then, we added accounts that show up on our large currency reports with some regularity, and therefore we keep a close eye on them, along with other accounts that we just feel need a close eye.

I think you'll be OK if you've identified the ones the OCC thinks are suspicious (from their list), and the ones that the examiners might see on your large cash report (ie the ones you know they're going to ask you about).

This is definitely a living document, and is quite helpful in building and maintaining a solid AML program.
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#99139 - 07/21/03 07:36 PM Re: OCC High Risk Accounts for BSA
Ruby Offline
Junior Member
Ruby
Joined: Feb 2003
Posts: 35
The way we've handled this is to make a list of all customers whose business type matches the high risk list in the OCC's handbook. Then we did a review of several months account relationship history with the bank and ranked the accounts as low, moderate or high risk for money laundering. Any accounts rated high or moderate are monitored regularly for any suspicious activity. The list is updated at least quarterly to add newly opened accounts and to adjust the risk ratings for customers who are already on the list. We do also include customers whose business type doesn't match the OCC's high risk list, but whose account activity warrants additional monitoring.

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#99140 - 07/22/03 03:52 PM Re: OCC High Risk Accounts for BSA
MagicCity Offline

Power Poster
MagicCity
Joined: Apr 2003
Posts: 3,003
Fort Lauderdale, Florida
We coded all our business accounts that fell into the 22 OCC categories as High Risk and assigned a code of 1, 2 or 3 based on our knowledge of the customers. The examiners told us we did not have the leeway to put a code of 2 or 3 for lesser risk as the list of these industries are all High Risk as defined by OCC. So they are now all coded 1.

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#99141 - 07/22/03 04:04 PM Re: OCC High Risk Accounts for BSA
Ruby Offline
Junior Member
Ruby
Joined: Feb 2003
Posts: 35
Our OCC examiners just required us to be able to show that we had reviewed and risk rated each account that matched the high risk types and that we had an ongoing monitoring process, but let us assign the risk rating as we saw fit. I didn't realize how lucky we were that we were allowed some leeway.

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#99142 - 07/22/03 05:18 PM Re: OCC High Risk Accounts for BSA
Miss Kitty Offline
Platinum Poster
Joined: Mar 2002
Posts: 721
California
Not to derail this from OCC, but what about FDIC? Has anyone had or going through a review where the risk assessment has/is surfacing?

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