Introductory BSA AML Examiner School Manual Palm Springs 2019

Customer Due Diligence

Policy Expectations

✓ Commensurate with the bank’s BSA/AML risk profile, paying particular attention to higher-risk customers.

✓ Contain a clear statement of management’s overall expectations and establish specific staff responsibilities, including who is responsible for reviewing or approving changes to a customer’s risk rating or profile, as applicable. ✓ Ensure that the bank possesses sufficient customer information to implement an effective suspicious activity monitoring program.

Customer Due Diligence

Policy Expectations

✓ Provide guidance for documenting analysis associated with the due diligence process, including guidance for resolving issues when insufficient or inaccurate information is obtained.

✓ Ensure the bank maintains current customer information.