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Course description

ICB Credit: 2.5 CRCM

Do You Know Your Customer? 

FinCEN says that “Banks specifically are expected to “obtain information at account opening sufficient to develop an understanding of normal and expected activity for the customer’s occupation or business operations.” In short, to understand the types of transactions in which a particular customer would normally be expected to engage necessarily requires an understanding of the nature and purpose of the customer relationship, which forms the baseline against which aberrant, suspicious transactions are identified. It was this fundamental expectation that FinCEN sought to encapsulate in its articulation of the third element of Customer Due Diligence. Other relevant facts could include basic information about the customer, such as annual income, net worth, domicile, or principal occupation or business, as well as, in the case of longstanding customers, the customer’s history of activity. “ 

How important is the new account interview to completing the third element of Customer Due Diligence? Critical! 

The New Account Interview has become critical to establishing the third element of Customer Due Diligence. There are also many other regulatory and compliance issues that get addressed in the first minutes we meet a new customer—both personal and business. During this program we will examine the compliance elements of the new account interview. 

Program Highlights: 

Part I Personal Accounts 

Nature and purpose of the account 

Identification on consumers 

Establishing tax home 

Asking transaction questions 

Product Disclosures

Regulatory Disclosures 

Placing holds 

Overdraft privilege 

Risk rating the customer 

Part II Legal Entity Accounts 

Nature and purpose questions 

Products and Transactions 

Special risk questions-MSBs, MRBs, TTTPs etc 


Beneficial owners and controlling person 

Business account documentation 


New Accounts, Personal Bankers, Branch Administration, Deposit Operations, CIP Managers, BSA Officers, Training and Business Development Personnel


Deborah Crawford

Deborah Crawford is the President of gettechnical inc. She specializes in compliance and regulations for the deposit side of financial institutions. Her 27+ year career in banking and training began at Hibernia National Bank. She has been a seminar leader for many state associations and credit union groups across the nation. She has Bachelors and Masters degrees from Louisiana State University.

Course curriculum

  • 1


    • New Account Interview: Updated for New CDD Requirements

  • 2


    • Materials

    • Slides

    • Questions and Answers