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High Risk Customer Identification and Monitoring - 2016
Brian Crow Recorded on June 16, 2016
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
Professional Service Providers
Cash Intensive Businesses
This session will not consider the new customer due diligence requirements for the beneficial ownership final rule.
Brian Crow, CAMS is Managing Partner & Co-President at Thomas Compliance Associates, Inc. in Chicago, IL.
Brian’s passion for and skill in protecting bank assets from fraud and compliance losses have earned him the nickname “Security Evangelist.”
In addition to developing and guiding the strategic vision for TCA, Brian delivers focused educational support to clients and helps them manage TCA’s suite of consulting, audit, and training services.
He is a nationally recognized expert on BSA/AML and deposit compliance and is a regular speaker at the annual BSA/AML Top Gun Conference.
As an education consultant for the Glia Group BOL Learning Connect program, Brian conducts webinars on topics like VISA/MasterCard chargebacks, debit card compliance, and fraud prevention. For this work, he was recognized as a Bankers Online Guru in 2011.
“Bach to Spock” could characterize his interests outside work. Music has been a lifelong passion, and Brian is the organist and handbell director for King of Glory Lutheran Church in Elgin, Illinois. And as a devoted Trekkie, he can hold my own with anyone in a Star Trek trivia match.