Does Your Customer’s Money Arrive in an Armored Car?
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Last week I was pleased to present a discussion titled “Conducting a Comprehensive BSA/AML/OFAC Risk Assessment” to the Florida International Bankers Association AML Compliance Committee. Many of the 50 attendees were surprised at some of the data we shared. Even if they thought their risk assessments were thorough, some of our charts opened their eyes to new risk data. In one example, we reviewed some indicators of inherent risk for both BSA/AML and OFAC. Most banking professionals know that cash-intensive businesses and foreign corporations are high risk, but here are a few interesting high-risk indicators that may not be on your radar as you review your customers:
- Customers using armored cars
- Privately owned ATMs
- Embassies and consultates
- Professional service providers (!)
There’s much more to know about bank regulatory compliance, and it’s best to get in front of it to protect your institution. I’m available to discuss your specific situation or to share more of the information we presented to FIBA.
Ivan Garces, CPA, is a Chief Risk Officer, Risk Advisory Services Practice Leader at Kaufman Rossin, one of the Top 100 CPA and advisory firms in the U.S.
