High-risk customer reviews have been a requirement since the first FFIEC Examination Manual was published in 2005. Recent guidance for Customer Due Diligence/Enhanced Due Diligence (CDD/EDD) further defines the expected approach for institutions to properly identify and evaluate high-risk customers. The regulators do not, however, detailed the day-to-day approach required to meet the required customer monitoring.
WHY SHOULD YOU ATTEND?
This presentation will provide the practical steps you can use to enable your institution to meet both the letter and spirit of the law and regulation related to identifying and monitoring high-risk customers. Learning from real-world audit issues, the presentation will cover what many financial institutions are doing incorrectly and what they should be doing instead to monitor these high-risk customers.
AREA COVERED
- Background related to the need for information about high risk customers
- FFIEC guidelines for determining high risk customers
- FinCEN expectations for a good high risk customer program
- Items to include in your high risk program
- Current issues related to the high risk process
- Recent enforcement actions addressing weak high risk programs
LEARNING OBJECTIVES
- An overview of FinCEN, FATF, and other financial regulatory requirements.
- Defining and clarifying the written requirements of the spirit of the law.
- Three common mistakes financial institutions make when identifying high-risk customers.
- How to ensure existing and new high-risk customers are identified properly.
- How to conduct high-risk customer reviews that have tangible benefits for your BSA Program.
- Real-life examples of high-risk customer reviews with tips on how to use these reviews for a financial institution’s environment.
- How to avoid examiner and regulator criticism regarding high-risk customer reviews.
WHO WILL BENEFIT?
- Account opening staff
- Risk managers
- BSA/AML Officers
- Compliance Officers
- BSA/AML Audit staff
This presentation will provide the practical steps you can use to enable your institution to meet both the letter and spirit of the law and regulation related to identifying and monitoring high-risk customers. Learning from real-world audit issues, the presentation will cover what many financial institutions are doing incorrectly and what they should be doing instead to monitor these high-risk customers.
- Background related to the need for information about high risk customers
- FFIEC guidelines for determining high risk customers
- FinCEN expectations for a good high risk customer program
- Items to include in your high risk program
- Current issues related to the high risk process
- Recent enforcement actions addressing weak high risk programs
- An overview of FinCEN, FATF, and other financial regulatory requirements.
- Defining and clarifying the written requirements of the spirit of the law.
- Three common mistakes financial institutions make when identifying high-risk customers.
- How to ensure existing and new high-risk customers are identified properly.
- How to conduct high-risk customer reviews that have tangible benefits for your BSA Program.
- Real-life examples of high-risk customer reviews with tips on how to use these reviews for a financial institution’s environment.
- How to avoid examiner and regulator criticism regarding high-risk customer reviews.
- Account opening staff
- Risk managers
- BSA/AML Officers
- Compliance Officers
- BSA/AML Audit staff
Speaker Profile
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 …
Upcoming Webinars
2-Hour Virtual Seminar on How to Conduct an Internal Harass…
FDA Audit Best Practices - Do's and Don'ts
Emotional Intelligence: Mastering the Emotions of Great Lea…
Regulation update Q1 2025: New and Proposed Regulations for…
Successful Strategies for FDA Expedited Pathways for Your D…
Unlock Employee Loyalty: Stay Interviews Will Keep Them Eng…
Accounting For Non Accountants : Debit, Credits And Financi…
Designing Employee Experiences to Build a Culture of Compli…
Pay Transparency in Action: Strategies for Building Trust a…
Developing and Implementing Quality Culture in the Organiza…
Reinvent Your Business with the Power of AI
Excel Lookup Functions: VLOOKUP, HLOOKUP, and XLOOKUP Made …
Tips and Techniques for Conducting an Effective Fraud Risk …
Break Free from Toxicity: Reclaim Your Power and Peace
Measure the Effectiveness of Compliance Programs by Engagin…
Physician Employment Agreements: Problem Areas that can be …
FDA Regulation of Artificial Intelligence/ Machine Learning
Onboarding Best Practices for 2025: Proven Strategies to Po…
Quality Management Systems and Data Integrity
Computer System Validation (CSV) 3-Hour Boot Camp
Cleaning Data without Complex Functions - A Course for Data…
Implementing an Effective Human Error Reduction Program
Navigating 2025 Employment Laws: What Every Employer Needs …
Succession Plan for 2025: It's Not Just for Emergencies - I…
Employers Should Prepare for Immigration Raids in 2025! Thi…
Managing Toxic Employees: Strategies For Leaders To Effecti…
Using High-Performance Coaching for Managers to Address Per…
21 CFR Part 11 - Compliance for Electronic Records and Sign…
Negotiating Skills For Professional Results - Winning Strat…
Principles & Practices for the Cybersecurity of Legacy Medi…
Tattoos, hijabs, piercings, and pink hair: The challenges …
6-Hour Virtual Seminar on Learning the Highlights of Excel …
How to Lead and Manage a Narcissistic Manager
Building Thriving Teams: Proactive Strategies for Managers …
ChatGPT and Project Management: Leveraging AI for Project M…
Reduce Stress in the Workplace: Effective Ways to Handle Co…
Stress, Change And Team Resilience Through Humor: An Intera…
The Importance of the first 5 seconds when presenting
GAAP—Update on new Accounting Principles and How They Impac…
Creating Employee Handbooks that Protect You and Support th…
ChatGPT and Project Management: Leveraging AI for Project M…