Introductory BSA/AML Examiner School, Atlanta, CA

Customer Due Diligence

Information Used to Determine Risk

• Obtained at account opening and throughout the relationship. ✓ Proximity to the customer’s residence, place of employment, or place of business to the bank. ✓ Description of the customer’s primary trade area and whether international transactions are expected to be routine. ✓ Description of business operations, the anticipated volume of currency and total sales, and a list of major customers and suppliers. ✓ Explanation for changes in account activity.

Customer Due Diligence

Exam Procedures

1. Determine whether the bank’s CDD policies, procedures, and processes are commensurate with the bank’s risk profile. Determine whether the bank has processes in place for obtaining information at account opening in addition to ensuring current customer information is maintained.