ABA Banking Journal - April 2010 - (Page 44)
compliance clinic | COMMUNiTY BaNK BSa/aMl riSK Up-front due diligence detects risks before committing Best due-diligence tools walk into the prospect’s place of business She may not actually bring a pair of white gloves along, but when Elizabeth Snyder visits a new banking prospect, she brings common sense to the inspection. Case in point: a new would-be customer that claims to be in the grocery business. “If they say they’re a grocery store, I want to see groceries in the aisle, and not with dust on them,” says Snyder. Anything that looks out of place, or anything that looks too unused, or anything at all that doesn’t synch with the kind of business that the potential customer claims to be in is a signal to Snyder that the bank must stop and evaluate. The bank 44 | ABA BANKING JOURNAL | april 2010 By Steve Cocheo, executive editor may decide to take a walk. That’s why Snyder, senior vicepresident and chief compliance officer at $676.8 million-assets Leaders Bank, believes site visits must play a part in the Oak Brook, Ill., bank’s enhanced due diligence efforts for Bank Secrecy Act/Anti-MoneyLaundering compliance. “Certain businesses require a site review even before we can consider taking them on as a customer,” explains Snyder. Check first, then sign up A key element to Leaders Bank’s enhanced due diligence process is the belief that no prospect should begin doing business with the bank until they’ve been vetted. Not all banks take this view, some determining that the due diligence can take place once the customer is on board. Snyder, speaking late last year at the Money Laundering Enforcement Conference sponsored by ABA and the American Bar Association, said that Leaders’ management believes otherwise. “We decided that we had to determine risk at account opening,” said Snyder. “We felt that if you waited a couple of days, you’d start to run into problems. Now you’d have a loan that’s been booked, or an account relationship that’s been
For optimal viewing of this digital publication, please enable JavaScript and then refresh the page. If you would like to try to load the digital publication without using Flash Player detection, please click here.