Risk Assessments Customer Risk

Transcription

1 FIBA Conference 2014 Risk Assessments Customer Risk María de Lourdes Jiménez, Esq Senior Vice President, Popular Inc

2 Customer Risk Ranking Benefits / Features Customer Risk Ranking System based on scoring of multiple factors Calculate customer s risk level at account opening based on an interactive script of questions that carry values based on type of business and expected activity Customer risk categories established based on NAICS and/or profile information Automated Reasonability Analysis which calculates variances based on expected to actual activity generate quarterly alerts triggered using the account open date Process performs periodic risk rating evaluations of the whole customer base Risk will be increased or lowered throughout the life of the relationship as a result of changes to the initial customer / account profile information Additional factors such as SARs filed, Subpoenas, 314(a) requests received, and adverse media information will automatically increase the customer s risk ranking Dynamic process - customer profiles do not go stale Documents are kept in sole repository advantage of single data sources 1

3 Understand Well Your Customer Base from inception Risk ranking at account opening based on Low, Medium, and High categories Commercial risk ranking based on NAICS & Risk Aggravating Factors (Private ATM, RDCS, MSBs Agent, Cash sales/income, High Risk Geography, etc) Consumer - risk ranking based on product profile and customer demographics, including citizenship, occupation, country of residence, PEPs status, etc Customer Risk Assessment Automated Quarterly Reasonability Analysis calculated for all customers based on date of account opening Customers that reflect a variance score exceeding the established tolerance due to this calculation will generate Quarterly Reasonability Alerts to confirm the situations that generated the profile deviation Periodic Visits / Customer communications Risk will be increased or lowered throughout the life of the relationship as a result of changes to the initial customer / account profile information Risk Assessments 2

4 Customer Risk Ranking complements Customer Due Diligence Program Customer Risk Ranking Customer categories and risk ranking Enhance Due Diligence tool Document Initial & Periodic visit Automates Reasonability Analysis Monitoring of customer s expected profile W/T, Cash, ACH, Checks Provides periodic Visit Plan Continuous assessments of customer risk profile Account Transactional Surveillance & Monitoring AML tool for the detection and analysis of unusual activities Exceptions based on total account profile and/or report parameters Monitoring of transactional profile Account Risk Score 3

5 Phases of Customer Risk Ranking Reasonability Analysis (RA) Automated Quarterly RA calculated for all customers based on account open date information Customers that reflect a variance risk score of 100 pts. or more due to this calculation will generate Quarterly Reasonability Alerts High Risk Customers with aggravating factors will require a Periodic Site Visit High Risk Customers that do not require a Periodic Site Visit will require a Periodic Profile Review based on the total customer risk score Quarterly Reasonability Alerts Maintain the information up to date through communication with customers prevents profiles from going stale Document customer profile activity variance and / or update Customer Profile Periodic Site Visit Customer that require a site visit will be reviewed by Branch Manager or Relationship Officer Before the site visit is performed the officer will review the Customer RA to confirm during the site visit any events / transactions that might have increased the customer score in the RA Customers ranking High Risk with aggravating factors will require a periodic site visit and RA regardless of the variance points Ej. Private ATM s, RDC, MSBs. Periodic Profile Review Customer risk score triggers*: 12 mo mo 300 to mo 100 to 299 *Aggravating factors override Review is performed by a centralized unit to confirm the reason of any score increase due to RA Document customer profile activity variance and / or update Customer Profile If reasonability is not attained, the Unit will contact the branch managers or relationship officer to obtain reasonability information from customer 4

6 Roles & Responsibilities Branch Platform: Complete KYC and KYA script at account opening Branch Assistant Manager: Perform Quality Review Branch Manager/CBC or Corporate Responsible Officer: For High Risk Customers complete CDD / EDD process, including Site Visit (if needed) Document within CRR KYC/KYA profile changes as a result of conclusions due to reasonability analysis alerts and / or site visits Branches / Corporate Retail & Corporate Centralized Units Review of Quarterly Reasonability Analysis for the whole customer base Periodic review of High Risk customers that do not require a site visit Periodic update of SARs, 314(a), PEPs, Subpoenas, and Adverse media data Quality Review of new High Risk customers (with & without initial visit) Quality Review of Reasonability Analysis performed to High Risk Customers Quality review of Quarterly Alerts of the whole customer base Periodic reports (Cash, W/T, ACH, ATM, RDC) BSA/AML CRR Unit CRR BSA Liaisons Perform Quality Review of Branch Process for all new accounts that scored High Risk Perform Quality Review of Reasonability Analysis Alert responses Perform follow up process of initial and periodic visit schedules Compliance support imbedded in the business units 5