Introductory BSA/AML Examiner School, Atlanta, CA

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)