Customer Due Diligence & Risk Profiles

Customer Due Diligence (CDD) is an essential piece of your overall BSA/AML/CFT Program. When we conduct a BSA/AML/CFT audit, we first look at whether you have written, risk-based procedures to assess the risk for each customer. Then, we determine if they are commensurate with your institution’s overall risk profile and whether they are sufficient to develop a customer risk profile. As you know, not all customers are created equal. For many, you will determine that they are very low risk. Others could be very high-risk. They key is that your CDD procedures are not only designed to detect this upfront but also to adjust with any changes to a customer’s risk profile.

Kevin explains more in the video.


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Published
2025/05/23

 
Kevin Edwards

Kevin Edwards

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).

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