There is a regulatory expectation to perform customer due diligence (CDD) on all high risk customers such as independent ATM owners, non-profit organizations (NPOs) and politically exposed persons (PEPs).  The Federal Financial Institution’s Examination Council (FFIEC) has recognized these entities should not automatically be categorized as high-risk.   The agency clarified and updated its due diligence expectations and moved from CDD that is required to be collected regardless of risk to risk-based CDD collection.  Financial institutions should be cautioned that this update is not a “get out of jail free” card and not a pass to stop collected due diligence on these entities.  While the expectations may have changed, it is incumbent on financial institutions to have the building blocks in place to collect the appropriate amount of CDD which will allow for an accurate risk assessment of the entity and guide the institution on how much additional due diligence should be collected.  

This information packed 60 minute webinar will review the November 2021 FFIEC updates to clarify the expectation set forth with new guidance.  The presentation will map the changes in comparison to the old guidance and provide clarity on what is expected. We will provide tools which will aid in determining when an ATM owner, NPP or PEP may be considered lower risk and when additional monitoring would be appropriate.  The session will also lay groundwork on how to apply this risk-based approach to other high-risk customers of the institution.