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Managing Compliance With Your Customer Identification ... - IIR

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Internal Information Sources – The Details:<br />

Identify and inventory the types of lists and how<br />

used<br />

Determine practice standards for lists and key<br />

events :<br />

•Appearance on government list,<br />

•Filing of suspicious activity report,<br />

•Account closure or termination of relationship<br />

•Receipt of criminal subpoena<br />

•Involvement in loss or fraudulent transaction<br />

•Subject of internal investigation<br />

•Negative press (financial or otherwise)

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