$3 Billion Bank CIP Program

Background:

Consulting activity with a $3B bank on instituting a CIP Program with CDD Risk Ratings for ongoing compliance to meet Audit and Regulatory Exams according to the FFIEC Rules and Regulations.

Solution:

Consulting with BSA, Risk (Consumer and Commercial), and Compliance Management updating policy and procedures, instituting training for front office and back-office staff for the mandatory collection of required CIP data and CDD processes at new account openings filling in the blanks on existing customer relationships. The updated policy and procedures outlined all the required fields for collection, risks associated, and why they were required. The dashboarding oversight was completed to ensure reporting and collaboration when fields having missed or blank information on a month over month basis. The dashboard clearly showed when appropriate actions for obtaining the information was required or timing for closure actions of the customer relationship.

Outcome:

After instituting the updated CIP and CDD policy and procedures and training bank staff, the BSA/AML Program received Two Consecutive Satisfactory Results from Annual Internal Bank Audits and Federal Exams. The BSA/AML Program was commended on the implementation of the process and dashboarding oversight with the ability to follow up as needed, by Board of Directors, Auditors and Examiners.