Introductory BSA/AML Examiner School, Providence, RI
Customer Due Diligence
Enhanced Due Diligence (EDD) • EDD is needed for higher risk customers. • Higher risk be due to: – Business activity – Ownership structure – Anticipated/actual volumes & types of transactions – Transactions with higher risk jurisdictions • Higher risk customers and their transactions should be reviewed closely at account opening and more frequently throughout their relationship with the bank.
Customer Due Diligence
Information Used to Determine Risk • Obtained at account opening and throughout the relationship. Purpose of account. Source of funds & wealth. Individuals w/ ownership or control over the account (beneficial owners, signatories, or guarantors). Occupation or type of business (of customer or ownership or control over the account).
Financial Statements Banking References Domicile (where the business is organized)
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