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.
basic component of a good Know-Your-Customer Program is identifying and
monitoring high-risk customers. In order
for a financial institution to properly conduct customer account review and
monitoring, the institution must risk rate its customers and determine those
that are higher risk and -risk so these accounts can be monitored more closely.
Webinar Learning objectives:
overview of FinCEN, FATF, and other financial regulatory requirements.
and clarifying the written requirements of the spirit of the law.
common mistakes financial institutions make when identifying high-risk
to ensure existing and new high-risk customers are identified properly.
to conduct high-risk customer reviews that have tangible benefits for your BSA
examples of high-risk customer reviews with tips on how to use these reviews
for a financial institution’s environment.
to avoid examiner and regulator criticism regarding high-risk customer reviews.
related to the need for information about high risk customers
guidelines for determining high risk customers
expectations for a good high risk customer program
to include in your high risk program
issues related to the high risk process
enforcement actions addressing weak high risk programs
one should attend:
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.
line BSA/AML staff
Thomas E. Nollner has more than 38 years of experience in financial institution supervision and consulting. Mr. Nollner spent 30 years as a National Bank Examiner (NBE) for the Controller of the Currency where he was a safety and soundness examiner and a compliance examiner.
The last 15 years as an NBE and for the past 8 years as a consultant, Mr. Nollner has specialized as an AML/CFT examiner/consultant. In these roles he has analyzed financial institutions’ AML/CFT programs to ensure that they complied with applicable AML/CFT laws, rules, and regulations; he reviewed the suspicious transactions identification, monitoring, and reporting processes;he traced proceeds and transactions through several layers of activity; and he provided AML/CFT training for many different financial institutions.
currently works as a consultant for the Office of Technical Assistance (OTA), a
branch of the U S Treasury that assists developing countries with banking
issues. Mr. Nollner is assigned to the
Economic Crimes Team that focused on training, assisting, and mentoring the
staffs of the financial regulatory departments and financial intelligence units
of various countries regarding AML/CFT compliance. In this capacity, he worked in countries such
as Afghanistan, Iraq, Turkmenistan, Viet Nam, Honduras, Guatemala, Guyana,
Suriname, and Argentina developing AML/CFT examination procedures, providing
AML/CFT training and mentoring, and updating local AML/CFT laws and