No, there is no required list of questions. Customer Due Diligence simply requires that we obtain sufficient information at account opening to enable the bank to predict the types of transactions in which the customer is likely to engage. Information that can assist in this include the nature of the business, the source of funds, the anticipated deposit and withdrawal activity and the types of services the customer expects to utilize. Many institutions add specific questions to aid in identifying higher risk customer types as defined in the BSA Exam Manual such as MSBs and Privately Owned ATMs. This is a subjective area of BSA and should be based on the bank’s BSA/AML Risk Assessment.
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