High Risk Customer Identification and Monitoring

Recorded on June 16, 2016   |   With Brian Crow

High Risk Customer Identification and Monitoring

With Brian Crow
  • 1 Video
  • 3 PDFs
  • 2.0 hrs
Course description

ICB Credit: 2.5 CRCM

Current expectations are that risk-rating should be fluid and customer risks reevaluated as monitoring identifies changes in business line, transaction volume, or ownership. Anticipated activity gathered at account opening should be compared to actual activity to aid in suspicious activity identification. Enhanced due diligence procedures should be clearly defined in policy and procedure.

Gone is the due diligence "checklist "mentality you have may have experienced in the past. Institutions are expected to gather sufficient information at account opening to determine the reasonable and expected activity for every customer. For community banks this could number in the tens of thousands of customers, mid-sized banks hundreds of thousands and large banks, millions. The burden on a BSA Officer is significant.

Join Brian Crow for a detailed discussion on risk-rating methodologies and enhanced due diligence methods including:

  • Three risk rating methods, subjective, manual matrix and automated system
  • Anticipated Activity Questionnaires
  • The value (or lack thereof) of risk rating consumer accounts
  • Enhanced due diligence and monitoring requirements for high risk customers
  • ACH Originators including Third Party Processors
  • Remote Deposit Capture
  • Privately Owned ATMs
  • Non-Resident Aliens
  • Non-Government Organizations
  • Professional Service Providers
  • Cash Intensive Businesses

This session will not consider the new customer due diligence requirements for the beneficial ownership final rule.

Course Curriculum

Customer Risk Rating/CDD/EDD
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Brian Crow
Brian Crow

Brian Crow is Executive Vice President at Thomas Compliance Associates, Inc. in Chicago, IL. Brian brings 20 years of prior banking experience to the consulting field. He was most recently Assistant Vice President and BSA Administrator for a suburban Chicago bank, where his responsibilities included preparing the bank's annual BSA risk assessment and audit documentation. Earlier as Operations Officer at the same bank, Brian monitored AML activity, aided in the implementation of the bank's AML software, and designed the bank's authentication blocking program that helped to reduce debit card fraud losses by 95 percent. Brian's responsibilities also included managing the bank's Regulation E claims, managing the bank's courtesy overdraft program, reviewing Reg CC hold notices for accuracy, and processing claims for fraudulent signatures and endorsements.

Mr. Crow has been, and continues to be, an education consultant for BOL Learning Connect, conducting webinars that have covered VISA/MasterCard chargebacks, debit card compliance and fraud prevention for hundreds of banks. It was in this role that Mr. Crow was recognized as a Bankers Online Guru in 2011.

Like many of us, Mr. Crow began his banking career as a teller, working his way up to head teller and then branch management responsibilities. He earned a B.A. degree in Theology from Concordia University, River Forest, Illinois. Because of his education background, Brian has been given the unofficial title of "Security Evangelist" as he strives to help financial institutions protect their bottom line from losses related to fraud. You can contract Brian at b_crow@tcaregs.com.