High-risk customer reviews have been a requirement since the first FFIEC Examination Manual was published in 2005. Recent guidance for Customer Due Diligence/Enhanced Due Diligence (CDD/EDD) further defines the expected approach for institutions to properly identify and evaluate high-risk customers.The regulators do not, however, detailed the day-to-day approach required to meet the required customer monitoring.
This presentation will provide the practical steps you can use to enable your institution to meet both the letter and spirit of the law and regulation related to identifying and monitoring high-risk customers. Learning from real-world audit issues, the presentation will cover what many financial institutions are doing incorrectly and what they should be doing instead to monitor these high-risk customers.
Thomas E. Nollner has more than 38 years of experience in financial institution supervision and consulting. Mr. Nollner spent 30 years as a National Bank Examiner (NBE) for the Controller of the Currency where he was a safety and soundness examiner and a compliance examiner. The last 15 years as an NBE and for the past 8 years as a consultant, Mr. Nollner has specialized as an AML/CFT examiner/consultant. In these roles he has analyzed financial institutions’ AML/CFT programs to ensure that they complied with applicable AML/CFT laws, rules, and regulations; he reviewed the suspicious transactions identification, monitoring, and reporting processes;he traced proceeds and transactions through several layers of activity; and he provided AML/CFT training for many different financial institutions. Mr. Nollner currently works as a consultant for the Office of Technical Assistance (OTA), a branch of the U S Treasury that assists developing countries with banking issues. Mr. Nollner is assigned to the Economic Crimes Team that focused on training, assisting, and mentoring the staffs of the financial regulatory departments and financial intelligence units of various countries regarding AML/CFT compliance. In this capacity, he worked in countries such as Afghanistan, Iraq, Turkmenistan, Viet Nam, Honduras, Guatemala, Guyana, Suriname, and Argentina developing AML/CFT examination procedures, providing AML/CFT training and mentoring, and updating local AML/CFT laws and regulations.