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Regulatory Issues around CIP/CDD, and Risk Ratings


Bank assessed regulatory findings of missing customer information, risk rating of customers, customer due diligence, and past due alert reviews after a merger of a $6B and $7B bank. Passing the $10B Asset threshold subjecting the bank to high level of scrutiny.


Consulting on Project Plan for remediation of all past due alert reviews, updating policy and procedures, requiring the collection of CIP and CDD data fields at account opening. Development of a process to use customer historical data, open-source data, to fill in missing CIP and CDD expected activities. Tuning of alerts with the added CDD and Risk Rating information, including a lookback to ensure proper alert dispositions and identify any missed suspicious activity.


After remediation efforts were completed the BSA/AML Program received a Satisfactory – Audit and Regulatory Exam results. The Satisfactory Audit and Regulatory Exams continued for the next two annual audit and exam cycles showing sustainable and scalable processes were in place.

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