- Overview
- Establishing, performing, and reporting risk assessments
- Incorporating geographic risk in the risk assessment
- Updating risk assessments with changes or additions to company's products or services
- Updating risk assessments with higher risk clients
- Periodic reports to company's board or senior management
- Accounts and customers subject to CIP requirements
- Establish a written CIP
- Establish and maintain procedures for determining customer risk profiles
- Establish and maintain risk-based procedures for collection of customer identification information
- Establish and maintain risk-based procedures for verification of customer identification information
- Establish and maintain procedures for resolving lack of verification
- Ongoing monitoring of the customer relationships
- Establish and maintain recordkeeping procedures for CIP/KYC Information
- Establish and maintain procedures for comparing customer Identification information with government lists
- Establish and maintain procedures for customer notification
- Establish written procedures identifying and verifying beneficial owners
- Reporting and recordkeeping requirements
- Establish procedures for SAR decision-making process
- Ensure timely and accurate notification and filing of required reports
- Procedures for information sharing
- Periodic reports to company's board and senior management
- Establish and maintain procedures for identifying suspicious transactions and activities that must be reported
- Establish which records will be maintained
- Establish procedures for effective records management
- Establish procedures for information sharing
- Establish procedures for the reporting of foreign bank and financial accounts
- Establish procedures for retrieval and delivery of records if requested
- Identifying foreign bank and financial accounts that must be reported
- Developing, implementing, and updating a Sanctions Compliance Program
- Establishing procedures to ensure commitment by senior management
- Establishing, performing, and reporting risk assessments
- Implementing internal controls to ensure ongoing compliance
- Establishing procedures for independent testing and auditing
- Developing an OFAC training program
- Reporting and recordkeeping requirements
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