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Assess the appropriateness and comprehensiveness of the bank’s customer due diligence (CDD) policies, procedures, and processes for obtaining customer information and assess the value of this information in detecting, monitoring, and reporting suspicious activity.
The cornerstone of a strong BSA/AML compliance program is the adoption and implementation of comprehensive CDD policies, procedures, and processes for all customers, particularly those that present a higher risk for money laundering and terrorist financing.
If so, the bank should consider obtaining, both at account opening and throughout the relationship, the following information on the customer: As due diligence is an ongoing process, a bank should take measures to ensure account profiles are current and monitoring should be risk-based.
Banks should consider whether risk profiles should be adjusted or suspicious activity reported when the activity is inconsistent with the profile.
Under this approach, the bank should obtain information at account opening sufficient to develop an understanding of normal and expected activity for the customer’s occupation or business operations.
The concept of CDD begins with verifying the customer’s identity and assessing the risks associated with that customer.
Processes should also include enhanced CDD for higher-risk customers and ongoing due diligence of the customer base.
If there is indication of a potential change in the customer's risk profile (e.g., expected account activity, change in employment or business operations), management should reassess the customer risk rating and follow established bank policies and procedures for maintaining or changing customer risk ratings.
Much of the CDD information can be confirmed through an information-reporting agency, banking references (for larger accounts), correspondence and telephone conversations with the customer, and visits to the customer’s place of business.But if it were to be captured, taken to a zoo and made an object of study, it has been made into a document.