Developing a customer’s risk profile is essential to a sound BSA/AML program. Banks should have written procedures that allow them to understand the nature and purpose of an account relationship so that unusual or suspicious activity can be detected. Ongoing monitoring is also a necessity. There is actually quite a bit of flexibility allowed, and procedures will vary by bank and customer base. It’s not uncommon for us to go into banks where they are doing this, but their procedures are not formalized in writing.
Kevin explains more in the video.
Video Highlights:
- Financial institutions must have written, risk-based procedures for conducting customer due diligence.
- The customer risk profile should allow for ongoing monitoring and updating of information over time.
- The purpose of this is to understand normal activity so suspicious activity can be identified more easily.
Published
2023/05/11
Kevin brings years of experience and a unique perspective on regulatory matters to our clients. A self-proclaimed geek and accredited CRCM, Kevin is also a recovering attorney with experience as in-house counsel for a large regional bank and one of the leading national title insurance providers. For reasons unknown, Kevin decided to leave the safety and serenity of his desk job to seek fortune and glory as a wandering adventurer. Like a bank compliance version of Kwai Chang Caine, The Man with No Name or Don Quixote, he now travels the land seeking to help those in need and righting compliance wrongs, wherever he may find them. Kevin lives in Sioux Falls with his two children, who are surprisingly normal after having endured their father’s vivid imagination for their entire lives. He won’t admit to having any hobbies, because apparently “Regulations never sleep.” (While he does say this in his Batman voice, we’re pretty sure he’s joking.) From the looks of his Facebook page, he likes the outdoors and spending time with his large extended family (who seem like relatively normal people).
