High-risk customer reviews have been required since the first FFIEC Examination Manual was published in 2005, and customer due diligence and enhanced due diligence (CDD/EDD) guidance further defines how institutions should identify and evaluate high-risk customers. What regulators don't spell out is the day-to-day approach to monitoring.
This 60-minute webinar on identifying and monitoring high-risk customers fills that gap. It reviews FinCEN, FATF and other regulatory requirements, FFIEC guidelines for determining high-risk customers, and FinCEN's expectations for a good program.
You'll learn what to include in your high-risk program, three common identification mistakes, how to make sure new and existing high-risk customers are identified, and how enforcement actions have targeted weak programs.
WHY SHOULD YOU ATTEND?
This session gives practical steps for meeting both the letter and the spirit of the rules on high-risk customers. Drawing on real-world audit issues, it shows what many institutions get wrong, what to do instead, and how to avoid examiner criticism.
It suits account opening staff, risk managers, BSA/AML and compliance officers, and BSA/AML audit staff.
AREA COVERED
- Why institutions need information about high-risk customers
- FinCEN, FATF and other regulatory requirements
- FFIEC guidelines for determining high-risk customers
- FinCEN expectations for a good high-risk customer program
- What to include in your high-risk program
- Three common mistakes in identifying high-risk customers
- Current issues in the high-risk process
- Enforcement actions addressing weak high-risk programs
- Real-life examples of high-risk customer reviews
LEARNING OBJECTIVES
- Explain FinCEN, FATF and other requirements for high-risk customers
- Interpret both the written requirements and the spirit of the law
- Avoid three common mistakes in identifying high-risk customers
- Make sure new and existing high-risk customers are identified properly
- Conduct high-risk customer reviews that strengthen your BSA program
- Avoid examiner and regulator criticism of your reviews
WHO WILL BENEFIT?
- Account opening staff
- Risk managers
- BSA/AML Officers
- Compliance Officers
- BSA/AML Audit staff
This session gives practical steps for meeting both the letter and the spirit of the rules on high-risk customers. Drawing on real-world audit issues, it shows what many institutions get wrong, what to do instead, and how to avoid examiner criticism.
It suits account opening staff, risk managers, BSA/AML and compliance officers, and BSA/AML audit staff.
- Why institutions need information about high-risk customers
- FinCEN, FATF and other regulatory requirements
- FFIEC guidelines for determining high-risk customers
- FinCEN expectations for a good high-risk customer program
- What to include in your high-risk program
- Three common mistakes in identifying high-risk customers
- Current issues in the high-risk process
- Enforcement actions addressing weak high-risk programs
- Real-life examples of high-risk customer reviews
- Explain FinCEN, FATF and other requirements for high-risk customers
- Interpret both the written requirements and the spirit of the law
- Avoid three common mistakes in identifying high-risk customers
- Make sure new and existing high-risk customers are identified properly
- Conduct high-risk customer reviews that strengthen your BSA program
- Avoid examiner and regulator criticism of your reviews
- Account opening staff
- Risk managers
- BSA/AML Officers
- Compliance Officers
- BSA/AML Audit staff