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Course description

High risk customers are often seen as a resource drain that adds little to the bottom-line. It is time to challenge this view and work towards seeing high risk customers as adding value to your BSA program.

This program will address common audit issues and how to avoid them, sample high risk reviews, simple ways to streamline complex BSA/AML tasks, and challenged posed by new regulatory requirements, such as beneficial owner.

In this webinar you will learn how to perform effective analysis that provides a clear contextual view of the customer, which will directly affect and enhance the day-to-day operational efficiency of your BSA program, in spite of increasing customer due diligence and enhanced due diligence requirements.

This program will cover:

  • Common high risk customer types, such as third party payment providers, cash intensive businesses, private ATM owners, and politically exposed persons
  • Sample high risk customer reviews, highlighting what is typical and what should occur
  • How to develop a suitable risk assessment with unique risk factors to include in ongoing reviews
  • Sample steps for building a framework for all CDD/EDD efforts
  • How to reap the benefits of the efforts put into the high risk customer review process
  • Where and how to start implementing changes
  • Regulatory requirements and guidance
  • How to comply with the letter and spirit of the law (FFIEC's BSA/AML Exam Manual)
  • Common audit issues and how to avoid them
  • Practical fixes to assist in vetting operational compliance issues

Attendees will receive:

  • Sample high risk customer reviews, highlighting what is typical and what should occur
  • Sample steps for building a framework for all CDD/EDD efforts



Sarah Beth Whetzel

Sarah Beth Whetzel is a CAMS-certified consultant and founder of Palmera Banking Solutions. Most recently she directed the BSA Practice for a national compliance consulting firm. With 15 years of experience in compliance and risk management for financial institutions and technology companies, her expertise includes the management and performance of AML, BSA, and OFAC regulations in the form of AML system validations, AML remediation and BSA/AML compliance audits. Sarah Beth has broad experience working with bank technology companies as well as financial institutions of all risk profiles and sizes. Several areas of specialized expertise include banks, credit unions, trust/wealth management companies, non-bank financial service providers, bank technology providers, and insurance companies.In both auditing and operational roles, software has been at the core of her experience. She has an in-depth working knowledge of various core banking platforms as well as many of the top AML systems. She is recognized in the consulting and auditing industries for her ability to “operationalize” the complicated BSA/AML and OFAC regulations to custom fit unique operational environments and risk profiles. Sarah Beth displays the ability to think about technology in a way that is integrated from how operations and unique business environments are impacted by compliance. She discovers and closes the often-found gaps between intention (policies/procedures) and day-to-day compliance related action.The highlight of her banking career was when she served as Risk Manager and BSA Officer for a $5+ billion dollar, multi-state, financial institution with four wholly owned subsidiaries. During her time there, she took a failed BSA Program that was under an order and turned it around in less than 100 days, to include the creation of an enterprise-wide AML transaction monitoring system. Regulators stated that the BSA Program that she designed was the “most comprehensive” and “most efficient” of all the institutions under their purview. Prior to her banking career, she also developed a reputation for being a fraud prevention expert having managed fraud and transaction monitoring programs for one of the world’s largest transaction processors.Sarah Beth holds a Bachelor of Arts in Business from Taylor University and a Master of Science in Forensics (M.F.S.) from Stevenson University. She has been CAMS certified for over 10 years. Sarah Beth is a highly sought after speaker with engagements in the Caribbean and in the U.S. She started Palmera Banking Solutions in 2011 after seeing a need in the marketplace for specialized and affordable BSA/AML solutions.

Course curriculum

  • 1


    • Embracing High Risk Customers

  • 2


    • Slides

    • Addressing the Real Risks of PATMO's

    • Economic Citizenship in the US

    • The Paname Papers and Why you Should Care

    • Questions and Answers