Description:
Financial institutions are expected to collect sufficient due diligence at account opening and through ongoing monitoring to identify customers that are higher risk for money laundering and terrorist financing. What the regulation doesn’t tell us is how to interpret the information we collect to determine who is high risk. Additionally, certain higher-risk customer types do have specific guidance from FinCEN stating what documentation should be collected.
Even once we have checked all the boxes, our customer review is not complete. Regulators expect that we take all the due diligence pieces and put them together to demonstrate that we understand why the activity we’re reviewing is not suspicious. In this session, we discuss the various types of data that can help us understand our customers’ activity and explore some of the specific requirements for high-risk customers.
Key takeaways:
- Identify due diligence information collection best practices
- Evaluate customer risk-rating methodologies
- Identify specific due diligence requirements for certain high-risk customer types
- Identify suspicious activity red flags that require additional investigation
- Demonstrate a sample enhanced due diligence analysis
Reminder: The registration fee includes live attendance AND a playback recording of the session, available once the session concludes.
This session is eligible for Continuing Education (CE) credits by the American Bankers Association.
Presenters:
Brian Crow, CAMS
Brian Crow is managing partner and co-president for TCA Compliance and is a nationally recognized BSA/AML expert with a strong bank compliance management background and a welcome ability to provide focused educational support to TCA client banks. Crow most recently was BSA Administrator for a suburban Chicago bank, where his responsibilities included the bank’s annual assessment and audit documentation. Earlier, as Operations Officer at the same bank, Crow monitored AML activity and helped install automated AML software that allowed the bank to transition from paper to electronic CTRs. His activities were responsible for reducing debit card fraud by 95 percent at the bank. Mr. Crow has been, and continues to be, an education consultant for the Glia Group BOL Learning Connect program. It was in this role that 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 branch management responsibilities. He earned a B.A. degree from Concordia University, River Forest Illinois.
June 3, 2025