Introductory BSA AML Examiner School Manual Palm Springs 2019

MSBs Can Help Fight Money Laundering

What Should MSBs Look For? (Cont.) Customers Who Provide Insufficient and/or Suspicious Information Individual and business customers may try to evade providing required identification, such as: An individual customer who is unwilling or unable to provide identification or information. An individual customer who provides different identification or information each time he or she conducts a transaction. – Different name or different spelling of name. – Different address or different spelling or numeration in address. – Different identification types. An individual customer without a local ■ ■

address, who appears to reside locally because he or she is a repeat customer. A legitimate ID that appears to have been altered. An identification document in which the description of the individual does not match the customer’s appearance (e.g. different age, height, eye color, sex). An expired identification document. An individual customer who presents any unusual or suspicious identification document or information. A business customer that is reluctant to provide complete information regarding: the type of business, the purpose of the transaction, or any other information requested by the MSB. A prospective business customer that refuses to provide information to qualify for a business discount (or other preferred customer program offered by the MSB).

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