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Training Appropriate PersonnelTraining on monitoring and detecting suspicious activity was particularly weak atRiggs. For example, bank officer visits to customer business locations did not includeassessments of BSA/AML risk factors. In addition, branch personnel most familiar withaccounts held by money services businesses (“MSBs”) were unaware of the factors thattypically are associated with suspicious activity and the new BSA registrationrequirements for MSBs.
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