Implement senior management approval of all
relationships identified as high risk.
• Implement senior management review
process to exit from an existing high risk
relationships if risk level exceeds the entities
risk tolerance.
• Analyze money laundering and terrorist
financing risk vulnerabilities for new
acquisition processes and product or service
development processes.
• Conduct 3rd party determination when not
required to do so.
• Update 3rd party and correspondent banking
information on a more frequent basis.