BSA/AML Examination Manual - ffiec

Nondeposit Investment Products — Overview
Bank management should make reasonable efforts to update due diligence information on
the broker/dealer. Such efforts may include a periodic review of information on the
broker/dealer’s compliance with its BSA/AML responsibilities, verification of the
broker/dealer’s record in meeting testing requirements, and a review of consumer
complaints. Bank management is also encouraged, when possible, to review BSA/AML
reports generated by the broker/dealer. This review could include information on account
openings, transactions, investment products sold, and suspicious activity monitoring and
reporting.
In-House Sales and Proprietary Products
Bank management should assess risk on the basis of a variety of factors such as:
• The type of NDIP purchased and the size of the transactions.
• The types and frequency of transactions.
• The country of residence of the principals or beneficiaries, or the country of
incorporation, or the source of funds.
• Accounts and transactions that are not usual and customary for the customer or for the
bank.
For customers that management considers high risk for money laundering and terrorist
financing, more stringent documentation, verification, and transaction monitoring
procedures should be established. Enhanced due diligence may be appropriate in the
following situations:
• The bank is entering into a relationship with a new customer.
• Nondiscretionary accounts have a large asset size or frequent transactions.
• The customer resides in a foreign jurisdiction.
• The customer is a PIC or other corporate structure established in a higher-risk
jurisdiction.
• Assets or transactions are atypical for the customer.
• Investment type, size, assets, or transactions are atypical for the bank.
• International funds transfers are conducted, particularly from offshore funding
sources.
• The identities of the principals or beneficiaries in investments or relationships are
unknown or cannot be easily determined.
• Politically exposed persons (PEPs) are parties to any investments or transactions.
FFIEC BSA/AML Examination Manual 227 8/24/2007