BSA/AML Examiner School - Case Study Oct 2023

LCB12/15

Checklist 5.1: Customer Due Diligence (cont.)

Yes No

N/A

On the basis of a risk assessment, prior examination reports, and a review of the institution's audit findings, obtain sample CDD information for high-risk customers. Does the institution collect appropriate information and effectively incorporate this information into the suspicious activity monitoring process?

Y

Comments: Risk Rating — The Bank currently risk rates accounts during the account opening process. Review of the current risk rating forms indicates that samples provided by BBewC have not been updated to reflect AJ & R's specific risk. Recommendation — It is recommended that the BSA Officer update the current forms or obtain forms that reflect the Bank's specific risk. High Risk Accounts — Request list responses indicated that the Bank has one "High Risk" account. Account statements for August through October 2015 were reviewed. Activity on the accounts appears normal; no unusual or suspicious activity was identified.

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