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BSA/AML Examination Manual - ffiec

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Customer Due Diligence — Overview<br />

transactions, including those transactions involving high-risk jurisdictions. If so, the<br />

bank should consider obtaining, both at account opening and throughout the relationship,<br />

the following information on the customer:<br />

• Purpose of the account.<br />

• Source of funds and wealth.<br />

• Individuals with ownership or control over the account, such as beneficial owners,<br />

signatories, or guarantors.<br />

• Occupation or type of business (of customer or other individuals with ownership or<br />

control over the account).<br />

• Financial statements.<br />

• Banking references.<br />

• Domicile (where the business is organized).<br />

• Proximity of the customer’s residence, place of employment, or place of business to<br />

the bank.<br />

• Description of the customer’s primary trade area and whether international<br />

transactions are expected to be routine.<br />

• Description of the business operations, the anticipated volume of currency and total<br />

sales, and a list of major customers and suppliers.<br />

• Explanations for changes in account activity.<br />

As due diligence is an ongoing process, a bank should take measures to ensure account<br />

profiles are current and monitoring should be risk-based. Banks should consider whether<br />

risk profiles should be adjusted or suspicious activity reported when the activity is<br />

inconsistent with the profile.<br />

FFIEC <strong>BSA</strong>/<strong>AML</strong> <strong>Examination</strong> <strong>Manual</strong> 58 8/24/2007

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