Current expectations are that risk-rating should be fluid and customer risks reevaluated as monitoring identifies changes in business line, transaction volume, or ownership. Anticipated activity gathered at account opening should be compared to actual activity to aid in suspicious activity identification. Enhanced due diligence procedures should be clearly defined in policy and procedure.
Gone is the due diligence "checklist "mentality you have may have experienced in the past. Institutions are expected to gather sufficient information at account opening to determine the reasonable and expected activity for every customer. For community banks this could number in the tens of thousands of customers, mid-sized banks hundreds of thousands and large banks, millions. The burden on a BSA Officer is significant.
Join Brian Crow for a detailed discussion on risk-rating methodologies and enhanced due diligence methods including:
- Three risk rating methods, subjective, manual matrix and automated system
- Anticipated Activity Questionnaires
- The value (or lack thereof) of risk rating consumer accounts
- Enhanced due diligence and monitoring requirements for high risk customers
- ACH Originators including Third Party Processors
- Remote Deposit Capture
- Privately Owned ATMs
- Non-Resident Aliens
- Non-Government Organizations
- Professional Service Providers
- Cash Intensive Businesses
This session will not consider the new customer due diligence requirements for the beneficial ownership final rule.
While this was a review, there were additional clarifications made that will help in our BSA duties. - Compliance2/
Brian has a great deal of expertise.- rwood0490
Good, kept attention, never looked at clock - rwood0490