“Profession”: Should It Be Mandatory During Onboarding?
While anyone in the banking sector can speak to the importance of collecting complete and accurate customer information while onboarding, there is not a common consensus on what data should be mandatory.
Typical information that is provided during onboarding include the following:
- Date of birth
- Social security/social insurance number
- Government issued IDs (e.g. Driver’s License or Passport)
- Phone number
But what about other data that are often bypassed or not completed? I recently interviewed two AML compliance investigators, one in the US and the other in Canada, and they made a case for Profession/Occupation, Employer and Income as critical data for building a proper risk profile of the customer.
According to these investigators, one of the biggest challenges when doing their job was missing information in the CIP/CIF (customer identification program/customer information file). Without an occupation on file, it can be hard to get a full picture of whether a specific behavior is anomalous and needs investigation.
Although not mandatory fields per FinCEN reporting, professions are good to know for CTRs. They also go a long way towards helping with EDD reviews and SAR filing/alert reviews. Adding employer information provides even more context. Knowing someone is a “senior engineer” is helpful but knowing that someone is a “senior engineer at Schlumberger” is far more helpful.
In Canada, it is best practice is to collect employer, occupation and income to ensure that customers are not commingling illicit funds into the banking system. FINTRAC has included this data as required fields when filing a regulatory report and it is also highlighted under the PCMLTFA Section 11.42 (2)
Then there is a matter of keeping this data current. Hence there should be processes in place to request updated information for key customer activities such as adding a new financial product or increasing the limit on a line of credit.
Requiring tellers/branch personnel to collect profession/occupation and employer information during account opening phase is a small step but goes a long way towards identifying unusual behavior, such as monthly deposits of $17,500 from a Walmart cashier.
Besides profession/occupation and employer, what other data do you think is best practice in your financial industry? Tweet your answer to @CaseWareAlessa.
About Andrew Simpson
Andrew Simpson (LinkedIn | Twitter) is Chief Operating Officer at CaseWare RCM and has more than 20 years of experience building businesses in the fields of information systems audit and security, data analytics, Anti-Money Laundering and forensics. He is a regular contributor to conferences and a recognized thought leader in financial crime management.