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Risk, Resilience, and Rewards: How Financial Institutions can Handle High-Risk Customers

In the banking industry today, the relationship between regulatory compliance and risk management is interwoven more than ever. As the sun rose on the year 2024, it cast a revealing light on a landscape marked by rapid changes, daunting challenges, and unprecedented regulatory scrutiny. Bank and credit union leaders now find themselves at a crossroads, navigating a path fraught with obstacles yet rich with opportunities for innovation and strategic partnerships.


This rapidly transforming landscape has revealed a critical issue—the intensified scrutiny on the identification and management of high-risk customers. This heightened focus is a direct response to evolving regulatory standards, particularly in the wake of major financial scandals and increasing global attention on preventing money laundering, fraud, and financial crimes. 


Regulators, armed with stricter guidelines and enhanced enforcement capabilities, are now demanding more rigorous oversight from financial institutions. This shift reflects the need to mitigate immediate risks and underlines a growing emphasis on ethical banking practices. As a result, banks and credit unions are finding themselves under increased pressure to implement more effective strategies for managing high-risk customers. These strategies need to balance regulatory compliance with operational efficiency, ensuring that they can both identify potential risks proactively and respond to them effectively.


Understanding the Increased Scrutiny on High-Risk Customers


There has been a marked increase in the attention that bank examiners pay to how financial institutions identify and manage their higher-risk customers in recent years. This shift is partly in response to evolving regulatory standards and the need to mitigate risks associated with money laundering, fraud, and other financial crimes. Navigating this landscape effectively requires banks and credit unions to employ a combination of strategic planning, advanced technology, and comprehensive training.


Tips and Tricks for Banks and Credit Unions


Enhanced Customer Due Diligence (EDD)

  • Implement a robust EDD program for high-risk customers. This includes gathering comprehensive information about the customer’s business activities, source of funds, and the nature of their transactions.

  • Regularly (not bi-annually) update customer profiles and risk assessments to capture any changes in their risk profile.


Leveraging Technology

  • Utilize advanced analytics and machine learning algorithms to monitor transaction patterns and detect anomalies indicative of illicit activities.

  • Invest in customer relationship management (CRM) systems that integrate risk assessment tools for ongoing monitoring.


Risk Categorization

  • Develop a clear risk categorization framework. This should involve defining what constitutes a “high-risk customer” based on factors like geographical location, transaction types, and business sectors.

  • Regularly review and update the risk categorization criteria to align with changing regulatory landscapes and emerging risks.


Training and Awareness

  • Conduct regular training sessions for staff on the latest regulatory requirements and best practices in identifying and managing high-risk customers.

  • Foster a culture of compliance and risk awareness across all levels of the organization.


Transparent Policies and Communication

  • Maintain clear and accessible policies regarding the handling of high-risk customers. Ensure these policies are well communicated within the organization.

  • Establish clear lines of communication for reporting suspicious activities.


Collaboration with Fintechs

  • Consider partnerships with fintech companies that specialize in regulatory technology. These partnerships can provide access to innovative tools for risk management and compliance.


Documentation and Record-Keeping

  • Keep meticulous records of all due diligence activities, risk assessments, and decision-making processes regarding high-risk customers.

  • Ensure that documentation is easily retrievable for examination purposes.


Regular Audits and Reviews:

  • Conduct internal audits to evaluate the effectiveness of risk management strategies and compliance with regulatory standards.

  • Use audit findings to refine and strengthen risk management practices.


As we navigate this evolving landscape of banking that’s under rigorous regulatory scrutiny, effectively managing high-risk customers becomes paramount in ensuring the integrity and stability of financial institutions. This journey, though filled with challenges, presents a unique opportunity for banks and credit unions to demonstrate their commitment to ethical practices, innovative solutions, and operational excellence. By adopting these strategic approaches, financial institutions can meet regulatory demands and pave the way for a more secure and trustworthy financial future. 


Let's embrace these changes as stepping stones, leveraging them to fortify our systems and set new standards in banking excellence. Together, we can turn these obstacles into catalysts for growth and transformation


Be well.



Meet the Author:



Brian Nowak, Senior Compliance Specialist

Brian Nowak has spent over a decade in regulatory compliance and internal audit roles, including working as a safety and soundness examiner for the Federal Reserve System and holding senior executive positions at prestigious accounting firms. During his tenure at the Federal Reserve, he oversaw all aspects of examinations for both small and multi-billion-dollar financial institutions and bank holding companies. His specialties include evaluating various areas such as risk management practices, asset quality, earnings performance, interest rate risk management products, liquidity, internal controls, and management information systems.

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