We are a community bank located in a large, urban area. The types of customers who use our bank are changing. Every year, as the demographics in our area change, we wonder if we are more at risk for money laundering activities.

When should we change our AML program to reflect this perceived risk? It’s hard to remain confident that our current procedures will work as our neighborhood continues to change. We also want to keep a balance between customer service and AML compliance.

How often should we re-evaluate our risk for money laundering, and what's the best way to do this?

— Martin J., Compliance Officer

I understand the need for them ... I’m talking about the lists we all have to check against our customer databases. The OFAC Sanctions Program List and the Politically Exposed Persons (PEP) List are only two examples. I just wish they weren’t getting longer and more complicated every day.

I am worried that the more information I have to double-check, the less I can focus on customers. I want to stay compliant but still be customer-friendly.

How do other financial institutions monitor their lists? Is there a way to balance compliance and customer service?

— Maria Groves, Compliance Officer

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