High Risk Client Review

Types of BSA/AML Reports
 Account Structuring-Customer Reports
 Cashier’s Check Log-currently in Excel
 Wire Activity-Wire Workshop-export data to Excel
 Professional Service Providers-Customer Reports
 Non-profit Accounts-Customer Reports
 Micro ACH Debits-Customer Reports
 Micro Transfers-Customer Reports
Types of BSA/AML Reports
Abnormally High Incoming & Outgoing Wires-Fraud &
Check Kiting Workshop
Abnormally High ACH Credits & Debits-Fraud & Check
Kiting Workshop
Abnormally High Transfers-Fraud & Check Kiting
Cash with Wires-Customer Reports
Types of Reviews
1) High Risk Client Review-reviewing the activity of our high
risk clients
2) Watch List Review-reviewing the activity of clients within a
particular watch list
3) Snapshot Summary-A client hits one of our other
BSA/AML reports and we want to see a “snapshot” summary
of their activity
Risk Rating vs. Watch List
Risk rating ranges from 1 through 5
1 is the default for all consumer accounts
2 is for NRAs (higher risk consumers)
3 is the default for all business accounts
4 is high risk
5 is very high risk
Watch lists include a variety of groups such as
auto dealers, MSBs, cash intensive businesses,
Risk Rating vs. Watch List
• Annually, we conduct detailed reviews of
activity for risk level “4” clients
• Semi-annually, we conduct detailed reviews of
activity for risk level “5” clients
• Annually, we review the activity within certain
watch lists to detect transactions that may be
unusual or uncharacteristic to that watch list
High Risk Clients
If the client is on any of our BSA/AML reports
When the owners of a MSB have other businesses
If client has frequent foreign wires
When opening a new account, client indicates that
they will be conducting large amounts of higher-risk
activity (such as large amounts of cash or large
High Risk Client Review
 Conducted on high risk clients (level 4 and 5)
 Obtaining data for the review:
High Risk Client Review
The report lists all of the client’s activity for the time frame.
We then format the data to our liking and subtotal each
column based upon the transaction month.
High Risk Client Review
The credits and
debits are summed
for each month and
graphs are created
in a new worksheet
High Risk Client Review
Once the client’s activity has been reviewed,
we will click the “Reviewed” button on the Risk
Tab and assign a Next Review Date
High Risk Client Review
The review date and date of next review is
added to the activity log on the lower left hand
side of the Risk Tab.
High Risk Client Review
The client’s review is saved in an Excel
spreadsheet that we upload to the Risk Tab.
High Risk Client Review
Once the review is complete, we print the Risk
Review Research Report and place it in their
physical file.
Risk Review Research Report
The Risk Review Research Report
is a summary of the information
contained within the Risk Tab.
Risk Review Research Report
High Risk Client Review & the Risk
 Risk Tab allows us to save everything
related to the review of the high risk client
in one spot
 Risk Tab gives us a professional, easy to
read report to put in their file to document
the review
High Risk Client Review & the Risk
We can easily see when we a review is coming up by
accessing either the Customers with Risk Review Dates or
the Customers with Rick Rating Expiration Alerts report
located in the Risk Management Workshop
Watch List Reviews
 We use the Customer Layering reports to
review activity within certain watch lists
 Data yields top 25% of activity
Watch List Reviews
Since the watch list reports are ran as a
Custom>Customer report, once we have
reviewed transactions, we right click on the
client’s name and “set reviewed”
“Snapshot Review”
 For when a client appears on one of our other
BSA/AML reports
 Client activity can be compared to that of other
clients with the same NAICS code, watch list, or
to the client’s historical activity
 Helps us determine whether or not the activity
may be considered suspicious or unusual
Trans Summary Report
Trans Summary Report
Trans Historical Comparison
Trans Historical Comparison
Layering Reports
Layering Reports
Risk Review Research Report
Thank you for attending today’s
presented by Sara Smith
Contact Sara Smith directly
at 805.369.5292 or [email protected]

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