Performing the First Step in Reviewing and Revising the Customer Onboarding Program

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When tasked with leading a team in an internal review and potential revision of a financial institution's customer onboarding program, the first step that a compliance officer should perform is to review the institution's risk assessment.

The risk assessment is the foundation of a successful AML/CFT program, and it provides the necessary information to identify the risk profile of the financial institution's customers, products, services, transactions, and delivery channels. By reviewing the institution's risk assessment, the compliance officer can identify the areas where the customer onboarding program needs improvement and tailor the program to mitigate the risks effectively.

Furthermore, reviewing the institution's risk assessment will help the compliance officer identify the regulatory requirements that apply to the institution, and ensure that the customer onboarding program is designed to meet those requirements.

In contrast, revising training materials for frontline staff, conducting enhanced due diligence on high risk customers, and resolving substantive discrepancies in customer verification are important steps in the customer onboarding process, but they should come after the risk assessment has been reviewed and updated, as they are all dependent on the risk profile of the institution's customers.

In conclusion, reviewing the institution's risk assessment should be the first step that a compliance officer should perform when tasked with leading a team in an internal review and potential revision of a financial institution's customer onboarding program.