Can anyone recommend a sight where I can find a checklist of things to cover when reviewing a high risk customer. The OCC is examiner feels that reviewing activity in not enought. However, she is not suggesting anything to help the matter. We do the ID etc. at opening and daily review activity for spicious activity (we do the entire database)- not just High Risk). She said we must focus on the H/R. What do you do to cover this?

Can you describe what qualifies them as high risk?

For OCC Banks you should refer to the Comptroller Handbook for the Bank Secrecy Act. High risk entities are listed starting on page 5. The contents of this book should help you develop a monitoring program, as this is what the examiners are looking at.

I found the OCC book and will read through it. However, my book is dated 1996. With all the events in the past few years is there a better source? I know who we identified as high risk. Now I (the bank) wants to know what to do ongoing .

Try this:
http://www.occ.treas.gov/moneylaundering2002.pdf
OCC Booklet
Money Laundering:
A Banker’s Guide to
Avoiding Problems

Try the Comptroller's Handbook, BSA 09-2000, page 21.

PDF version here.

Not new, but newest.

Thanks Andy. This bank still is using the 9-1996 book.

The OCC also published the list in AL 2000-3. It's generic; non OCC supervised banks should consider it as well.

Since your OCC examiner is a source of criticism, but not counsel, I will repeat what an OCC examiner told an associate. (Remember, this is anecdotal, it is one examiner talking, not the agency.) This examiner suggested that this midwestern bank painstaking identify every customer that was classified as a high risk business and maintain a folder for each. As you indicate, monitoring should take place on a daily basis for all accounts. However, the high risk accounts were to receive a documented quarterly review where BSA, not customer service, personnel went through and evaluated all transactions, cash flow, payees etc. relative to the type of business the customer is in. The review was not to focus on cash, but all types of receipts and disbursements. The reviews were to be placed in the file.

You get the idea...

There are a lot of banks looking for the specifics of AML programs that the agencies, and now the law, require. The OCC's exmination handbook is the most current and the most helpful, but at 30 months old it is out of date.