BSA/AML Examiner School - Case Study Oct 2023

LCB12/15

Internal Controls Checklist 5.1: Customer Due Diligence

Yes No

N/A

Are the institution's CDD policies, procedures, and processes appropriate given the institution's risk profile? Does the institution have processes in place for obtaining information at account opening; in addition to ensuring current customer information is maintained? Do the institution's policies, procedures, and processes allow for changes to a customer's risk rating or profile?

Y

Y

y

• Determine who is responsible for reviewing or approving such changes. BSA Officer and BSA Assistant

If the institution's policies, procedures, and processes allow for changes to a customer's risk rating or profile, does the institution have a designated person who is responsible for reviewing or approving the changes, and is the review process adequate to maintain the integrity of the process? Does the institution have adequate enhanced due diligence procedures and processes to identify customers that may pose higher risk for money laundering or terrorist financing? Does the institution provide guidance for documenting analysis associated with the due diligence process, including guidance for resolving issues when insufficient information or inaccurate information is obtained?

Y

Y

Y

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