Regulatory Issues around CIP/CDD, and Risk Ratings

Background:

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.

Solution:

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.

Outcome:

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.