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.
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.
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.
Thomas Nollner
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 …
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