This presentation will provide the practical steps to enable your institution to meet both the letter and spirit of the law and regulation. Learning from real-world audit issues, the presentation will cover what many banks are doing incorrectly and what they should be doing instead.
Ongoing high risk customer reviews has been a requirement since the first FinCEN Exam Manual was published in 2005. The recent guidance for Customer Due Diligence/Enhanced Due Diligence (CDD/EDD) further defines the expected approach for institutions to properly identify and evaluate high risk customers. The regulators have not, however, detailed the day-to-day approach required to meet this required customer monitoring.
Ongoing high risk customer reviews has been a requirement since the first FinCEN Exam Manual was published in 2005. The recent guidance for Customer Due Diligence/Enhanced Due Diligence (CDD/EDD) further defines the expected approach for institutions to properly identify and evaluate high risk customers. The regulators have not, however, detailed the day-to-day approach required to meet this required customer monitoring.
Thomas Nollner
Thomas E Nollner has more than 35 years of experience in financial institution supervision and consulting. Mr. Nollner spent 30 years as a National Bank Examiner for the Comptroller of the Currency where he was a safety and soundness examiner and a compliance examiner. As a safety and soundness examiner he examined national banks for capital adequacy, asset quality, management issues, earnings concerns, and liquidity funding. As a compliance examiner, he examined national banks for compliance with consumer laws and regulations such as the Truth-in-Lending Act, the Real Estate Settlement Procedures Act, the Flood Disaster Protection Act, the Community Reinvestment …
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