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Course description

Current expectations are that risk-rating should be fluid and customer risks reevaluated as monitoring identifies changes in business line, transaction volume, or ownership. Anticipated activity gathered at account opening should be compared to actual activity to aid in suspicious activity identification. Enhanced due diligence procedures should be clearly defined in policy and procedure.

Gone is the due diligence "checklist "mentality you have may have experienced in the past. Institutions are expected to gather sufficient information at account opening to determine the reasonable and expected activity for every customer. For community banks this could number in the tens of thousands of customers, mid-sized banks hundreds of thousands and large banks, millions. The burden on a BSA Officer is significant.

Join Brian Crow for a detailed discussion on risk-rating methodologies and enhanced due diligence methods including:

  • Three risk rating methods, subjective, manual matrix and automated system
  • Anticipated Activity Questionnaires
  • The value (or lack thereof) of risk rating consumer accounts
  • Enhanced due diligence and monitoring requirements for high risk customers
  • ACH Originators including Third Party Processors
  • Remote Deposit Capture
  • Privately Owned ATMs
  • Non-Resident Aliens
  • Non-Government Organizations
  • Professional Service Providers
  • Cash Intensive Businesses


This session will not consider the new customer due diligence requirements for the beneficial ownership final rule.



Instructor(s)

Brian Crow

Brian Crow is managing partner and co-president for TCA Compliance and is a nationally recognized BSA/AML expert with a strong bank compliance management background and a welcome ability to provide focused educational support to TCA client banks. Mr. Crow most recently was BSA Administrator for a suburban Chicago bank, where his responsibilities included the bank’s annual assessment and audit documentation. Earlier, as Operations Officer at the same bank, Mr. Crow monitored AML activity and helped install automated AML software that allowed the bank to transition from paper to electronic CTRs. His activities were responsible for reducing debit card fraud by 95 percent at the bank. Mr. Crow has been, and continues to be, an education consultant for the Glia Group BOL Learning Connect program, conducting webinars that have covered VISA/MasterCard chargebacks, debit card compliance and fraud prevention for hundreds of banks. It was in this role that Mr. Crow was recognized as a Bankers Online Guru in 2011. Like many of us, Mr. Crow began his banking career as a teller, working his way up to head teller and then branch management responsibilities. He earned a B.A. degree from Concordia University, River Forest, Illinois.

Course curriculum

  • 1

    Video

    • Customer Risk Rating/CDD/EDD

  • 2

    Materials

    • Materials

    • Slides

    • Questions and Answers