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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.


  • 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.

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.


  • 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

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

Thomas E Nollner has more than 35 years of experience in financial institution supervision and consulting. Mr. Nollner spent 30 years as a National Bank Examiner for the Comptroller of the Currency where he was a safety and soundness examiner and a compliance examiner. As a safety and soundness examiner he examined national banks for capital adequacy, asset quality, management issues, earnings concerns, and liquidity funding. As a compliance examiner, he examined national banks for compliance with consumer laws and regulations such as the Truth-in-Lending Act, the Real Estate Settlement Procedures Act, the Flood Disaster Protection Act, the Community Reinvestment Act, and AML/CFT laws and regulations. His specialty was as an AML/CFT examiner, where he analyzed a bank’s AML/CFT program to ensure that it complied with applicable banking laws, rules, and regulations; he reviewed the bank’s suspicious transactions identification, monitoring, and reporting process; he traced proceeds and transactions through several layers of activity; and, he reviewed a bank’s processes and procedures to determine root causes of AML/CFT program weaknesses. Mr. Nollner currently works as a consultant for the Office of Technical Assistance (OTA), a branch of the U.S. Treasury that assists developing countries with banking issues. Mr. Nollner is assigned to the Economic Crimes Team that focused on training, assisting, and mentoring the staffs of the financial regulatory departments and financial intelligence units of various countries regarding AML/CFT compliance. In this capacity, he worked in countries such as Afghanistan, Iraq, Turkmenistan, Viet Nam, Honduras, Guatemala, Guyana, Suriname, and Argentina developing AML/CFT examination procedures, providing AML/CFT training and mentoring, and updating local AML/CFT laws and regulations.

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