Independent Banker - October 2018 - 66

Compliance
Confidential
You can help create a safer world
The very simple thing every financial institution can do.
There's an incredibly simple thing every financial institution
can do to help make the world safer from terrorism and other
crimes: Ask three more questions when customers want to
send money abroad.
Consider making it your practice to track the source of the
funds, the purpose of the transaction and any related documentation
the customer can provide. Requesting this information
helps weed out fraudulent activity and dissuade
criminals from doing business at your financial institution.
Gone are the days when a customer could set up a bank
account in the name of a shell company alone, without the
names of beneficial owners attached. Regulators took a
close look at how financial crimes are committed, and far too
often, criminals use the convenience of shell companies to
obscure their identities. By taking the veil off shell companies,
we bring light to the dark places criminal activity sometimes
lurks.
Since every financial institution needs to make operational
changes to meet this new requirement, why not go just a
step further to shine an even brighter light? Financial institutions
already need to update customer records, create new
onboarding procedures, and retrain employees. So this is the
perfect time to make your international transactions even
more transparent.
Not only does this make life harder for terrorists and other
criminals, but there is a clear upside for you and your customers.
Your international transactions are likely to be processed
faster because payment providers won't need to request
more detail. And, very importantly, you can help protect your
financial institution against regulatory risk and reputational
damage that could affect your bottom line.
Sometimes in life, going a simple step further can make all
the difference in the world.
This is one of those times.
If
this becomes your standard policy, no customer ever
needs to feel singled out or targeted. Your employees never
need to make tricky judgment calls about when to probe for
more information.
Seeking this information is just a small step beyond the
changes you are already required to make because of the
new FinCEN Customer Due Diligence rule that mandates the
name of a beneficial owner on all accounts.
The foregoing is an opinion piece for informational purposes
only and not for the purpose of providing legal advice.
About Western Union Business Solutions
Western Union Business Solutions is the go-to international
payments provider for more than 1,000 financial institutions
around the world. As a true expert in financial regulations, the
company has a global team of compliance specialists and
robust compliance systems to meet regulatory standards.
1-800-897-6333
financialinstitutions@westernunion.com
business.westernunion.com/financial-institutions
http://business.westernunion.com/financial-institutions
Independent Banker - October 2018

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