The number of high-risk, cash-intensive businesses is growing. But how do
you identify and monitor these depositors in a way that keeps your institution
out of regulatory trouble? Learn to successfully navigate the regulations
surrounding MSBs, MRBs, CBD-related businesses, and more in this timely
- Define cash-intensive businesses in policies and procedures
- Develop internal controls to protect against money laundering and fraud
- Use provided tools and resources to develop a comprehensive due diligence process
at account opening
- Establish monitoring procedures to identify potentially suspicious activity
- File accurate SARs for emerging areas of fraud
Cash-intensive businesses span a wide variety of industries, which can make it more
difficult to identify potentially unusual activities that would be considered high risk. The
risks to your institution can increase if you have not properly identified the business or
the source of deposited funds, or appropriately monitored the changes in account activity.
Money service businesses, private ATMs, marijuana-related businesses, and industrial
hemp/CBD-related businesses present even more risk.
This session will address how to mitigate these risks and safely keep your doors open to
cash-intensive businesses. It will detail the required policies and procedures you should
have in place to identify cash-intensive businesses at account opening and conduct
appropriate due diligence to ensure proper understanding of the accountholder’s normal
activity. It will also cover red flags that should be incorporated into your monitoring
process to identify potentially suspicious activity and take appropriate action.
Dawn Kincaid, Brode Consulting Services, Inc.
Dawn Kincaid began her banking career while attending The Ohio State University. She
has over 20 years’ experience in client service, operations, information technology,
administrative and board relations, marketing, and compliance. Most recently Dawn
served as the Senior Vice President of Operations for a central-Ohio-based community
bank, where she created and refined policies and procedures, conducted self-audits and
risk assessments, and organized implementation of new products and services. Dawn has
served in the roles of Compliance, BSA/AML, CRA, Privacy, and Security Officer. She has
led training initiatives, prepared due diligence information, completed a variety of
regulatory applications, coordinated internal and external audits and exams, and
presented for numerous state associations.