Identifying high-risk customers essential to effective SAR program
If your institution doesn't have the ability to monitor high-risk customers it's unlikely that you have an effective suspicious activity reporting program, said David Caruso, of Dominion Advisory Group in Virginia, in the Seven Deadly (AML) Sins panel this morning. Identifying these customers, he said, is a "predicate necessary to have a SAR program that's meaningful.
- Start by deciding how you'll determine which customers are high risk (by who they are, where they are from, and what they do)
- Think thoroughly about what drives your identification of high risk customers
- This should drive your SAR program
Remember 90 percent of recent enforcement actions mention organizations not filing SARs on high-risk customers.
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