Opening Accounts for High Risk Customers: Documentation, Scripts and Risk Mitigation

Today’s decision to bank or not to bank high risk customers has been called a movement to de-risk. De-risking means to choose not to bank a whole group of customers. This process is being criticized as perhaps not being in the best interests of the country since there will be groups who find it difficult to find banking services. It may send industries into virtual currency and cash which make them less transparent. Perfect examples of this are marijuana related businesses, money service businesses, nonresident aliens, payday lenders, third party payment processors.

Instead, it may make more sense and ultimately be good for the local institution and the national objectives of transparency, to bank the high risk customers whose risk we can manage. If you choose to bank some of the high risk customer groups, what should you be looking for and what paperwork and documentation should you get before you enter the relationship. This webinar will delve into scripts, documentation, and monitoring for high risk customers.

Covered Topics:

  • How to identify high risk account holders - NAICS, CTR exemptions, FFIEC Exam Manual
  • Account holder type and account holder behavior feed risk scores
  • What do we need to know about these high-risk account holders?
  • How can we monitor them? Change risk? Close relationships?
  • A special look at NRAs, PEPs, MSBs, NGOs and Cash Intensive Businesses
  • How do these account holders affect your overall institution risk rating?
  • Impact on policy, procedures and monitoring

Who Should Attend?

This webinar will benefit BSA officers, BSA support personnel, deposit operations, compliance officers, new accounts, branch operations, all branch personnel and training.