How To Identify & Monitor Your High Risk Customers

High-risk customer reviews have been a requirement since the first FFIEC Examination Manual was published in 2005. Recent guidance for Customer Due Diligence/Enhanced Due Diligence (CDD/EDD) further defines the expected approach for institutions to properly identify and evaluate high-risk customers. The regulators do not, however, detailed the day-to-day approach required to meet the required customer monitoring.

WHY SHOULD YOU ATTEND?

This presentation will provide the practical steps you can use to enable your institution to meet both the letter and spirit of the law and regulation related to identifying and monitoring high-risk customers. Learning from real-world audit issues, the presentation will cover what many financial institutions are doing incorrectly and what they should be doing instead to monitor these high-risk customers.

AREA COVERED

• Background related to the need for information about high risk customers
• FFIEC guidelines for determining high risk customers
• FinCEN expectations for a good high risk customer program
• Items to include in your high risk program
• Current issues related to the high risk process
• Recent enforcement actions addressing weak high risk programs

LEARNING OBJECTIVES

• An overview of FinCEN, FATF, and other financial regulatory requirements.
• Defining and clarifying the written requirements of the spirit of the law.
• Three common mistakes financial institutions make when identifying high-risk customers.
• How to ensure existing and new high-risk customers are identified properly.
• How to conduct high-risk customer reviews that have tangible benefits for your BSA Program.
• Real-life examples of high-risk customer reviews with tips on how to use these reviews for a financial institution’s environment.
• How to avoid examiner and regulator criticism regarding high-risk customer reviews.

WHO WILL BENEFIT?

• Account opening staff
• Risk managers
• BSA/AML Officers
• Compliance Officers
• BSA/AML Audit staff