In addition, when you use "business standards" in this case the industry codes, it demonstrates that you are working proactively in preventing, detecting, reporting, and correcting any signs of criminal or suspicious activity.
Eventhough, is not a requirement yet...I'm sure that on the next revision of the manual they might implement it...
You are a small bank, that's even better....you have fewer business customers do code now...than 2-5 years from today..
We are a 300M bank, and we are implementing the industry code for easy identification of HIGH risk accounts...
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[b]"Common sense is not so common." Voltaire~[u]