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Bank AML Monitoring and Record Keeping Program

Bank AML Monitoring and Record Keeping Program. Office of Technical Assistance James Wright. Risk Based. Begins with a good Know Your Customer Program Customer ID Risk Rating of Customer. Risk Factors. Customer Businesses Countries. High Risk.

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Bank AML Monitoring and Record Keeping Program

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  1. Bank AML Monitoring and Record Keeping Program Office of Technical Assistance James Wright

  2. Risk Based • Begins with a good Know Your Customer Program • Customer ID • Risk Rating of Customer

  3. Risk Factors • Customer • Businesses • Countries

  4. High Risk • Visit high risk corporate accounts within one month • Political Exposed Persons • Perform source of wealth inquiry

  5. Yearly Reports • Annually update re-approve high risk accounts

  6. Low risk accounts • Monitored yearly in order to decide whether they remain classified as low risk • Factors: • Persistent exceptions identified in the monitoring and more than one change in transaction profile • Change in activity or ownership

  7. Customer Changes • Reporting information internally of any activity or customer behavior that is inconsistent with what is the known or expected

  8. Customer Profile • Essential Information

  9. Transaction • Develop a profile of the customers anticipated transactions and use of bank services per month

  10. Risk Assessment • 1.Is the customer’s core business defined as high risk? • 2.Is the customer located in a high risk geography? • Based on number 2 and the bank products we expect customer to use, does the customer represent a high risk?

  11. Risk Assessment • Answers • No, products and geographies dealt with are consistent with normal business activity • Yes, • (management will approve account opening subject to high risk account monitoring)

  12. Reports • Monthly • Monitor non-cash individual transactions for the month • Aggregate cash transactions for the month • Aggregate cash and non cash transactions for the month

  13. Quarterly Reports • Review of High risk accounts and submit the reports to the compliance officer • Review politically exposed persons account activity and document in a standard form

  14. Record Keeping • Purpose • Aid Law Enforcement • Aid in Analysis (banks and examiners)

  15. Types of Records • Customer • Transactions

  16. Period of Time • Five years

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