The FFIEC's most recent BSA/AML Examination Manual states that customer due diligence information can be confirmed through banking references, correspondence, telephone conversations with the customer, and “visits to the customer's place of business.” Also, the manual specifically suggests conducting on-site visits for certain customers, such as third-party payment processors, cash-intensive businesses and money services businesses, among others.

For resources related to our guidance, please see:

• FFIEC BSA/AML Examination Manual, Section on Customer Due Diligence — Overview (“Much of the CDD information can be confirmed through an information-reporting agency, banking references (for larger accounts), correspondence and telephone conversations with the customer, and visits to the customer’s place of business. Additional steps may include obtaining third-party references or researching public information (e.g., on the Internet or commercial databases).”)

• FFIEC BSA/AML Examination Manual, Third-Party Payment Processors — Overview (“A bank may assess the risks associated with payment processors by considering the following: . . . Visiting the processor’s business operations center.”)

• FFIEC BSA/AML Examination Manual, Cash-Intensive Businesses — Overview (With respect to cash-intensive businesses, “for those customers deemed to be particularly higher risk, bank management may consider implementing sound practices, such as periodic on-site visits, interviews with the business’s management, or closer reviews of transactional activity.”)

• FFIEC BSA/AML Examination Manual, Nonbank Financial Institutions — Overview (“Depending on the level of perceived risk, and the size and sophistication of the particular MSB, banking organizations may pursue some or all of the following actions as part of an appropriate EDD review: . . . conduct on-site visits . . . . ”)