bank secrecy act / anti-money laundering (bsa/aml) compliance

INTERNAL CONTROLS - MONITORING Monitoring systems typically include: Employee identification or referrals; Manual systems; Automated systems; or Any combination. Member Due Diligence ProgramINTERNAL CONTROLS – MONITORINGMEMBER DUE DILIGENCE PROGRAM Member Due Diligence (MDD) Program Begins with verifying the member’s identity and assessingthe risks associated with that member. Enables the prediction of the types of transactions in whicha member is likely to engage. Assists in determining when transactions are potentiallysuspicious. Should include an enhanced MDD for high-risk membersand ongoing due diligence of that member base. Keep current member information.12