Good morning,
I am hoping to learn if there could be a better way of tracking / utilizing our High-Risk Customer List. Currently the list has customers we are monitoring due to certain activity which has been detected, or because of the products and services they use. I, as the BSAO, and the Retail Officers at each location, have access to the list to add and update customer activity. Daily reports and frontline staff are the main ways activity is detected; however questionable activity may also be documented on an internal investigation report which is forwarded on to me. There is a field to note if the customer was added to the HRL. No less than the end of every quarter, I remind the Retail Officers to review the list for their location and provide a recommendation as to if the customer should be removed or remain on for continued monitoring. During this time, the activity may warrant a formal SAR filing. This was something I previously oversaw and then would forward on the retail officers, but seeing as they have a more hands on way of learning about activity, we changed the way the information flows. Sometimes activity goes right to a formal SAR filing via the SAR committee. I have run into locations having no customer information entered, but there is a history of email correspondence about adding someone. I wonder if the process should be different in hopes the responsibility of the High-Risk List would be more on "the radar" of those not currently making time to enter customer information. All branch locations' HRL are viewable by all retail officers, so everyone is aware of customer activity.
thank you in advance for any suggestions!

Have you considered defining criteria that adds to a customer's risk score in a written procedure, and removing that from the retail officers' duties? Many times an employee in a retail function has different training and a different point of view (sales/ customer focused) than someone in a BSA position, and its sometimes better to keep the two functions totally separate for those reasons. Retail will say "John Doe would never do that., I've known them forever..".

If you are doing your risk rating manually, and not through an automated AML solution, a written process that you and your BSA team follow might make it easier than trying to get info from Retail on who should be high risk. Start with the examination manual and consider how the account was opened, what the transaction type and volume is, what their occupation/ business purpose is,, how long the account has been opened, etc.. to derive the risk rating (high risk customer, low risk customer, etc). From a retail officer impact to your customer risk determination, it may be easier to focus on internal investigation reports whereby they notify you of any potential concerns. You would then do a documented review of the customer's activity and make a determination if further monitoring is warranted and put them on your high risk customer list if the answer is yes.

greatly appreciated Alison!