This risk-based approach includes automated detection and risk scoring using the Verafin system. Verafin identifies the attributes of clients that have an inherently higher risk for illicit activities. For additional job aides, demonstrations, and resources for using Verafin click here.
After opening an account, Capital City Bank assigns a risk rating to each client. The bank then conducts Enhanced Due Diligence (EDD) reviews, using established customer risk model parameters, throughout the life of the relationship.
Client Risk Scores
Client overall risk scores are based on the following:
High-risk customer types:
- Bulk currency shipper
- Check cashers - under $1000 per item, per person, per day
- Internet gambling
- Marijuana-related Business (MRB)
- Private ATM Owner (PATMO)
- Professional Service Provider (PSP)
- Third-party Payment Processor (TPPP)
High-risk organizations:
- ACH Originator (ACHO)
- Cash intensive business
- Embassy, foreign consulate, or foreign mission
- Money Services Business (MSB) - greater than $1000 per item, per person, per day
- Non-bank financial institution
- Non-governmental Organization (NGO)
- Remote Deposit Capture (RDC)
Independent Account Requirements
Many financial institutions choose not to establish banking relationships with check cashers, money service businesses, or private ATM owners. Capital City Bank requires these special account types to have independent accounts for all transactions pertaining to the check casher, money service business, or private ATM transactions. These independent accounts ensure the separation of funds from everyday operating expenses.
The Bank Secrecy Act and Anti-Money Laundering regulations require banks to conduct extensive monitoring of the cash and transactional activity in such accounts. One of the objectives of the required monitoring is to determine the source and use of funds flowing through these accounts. The bank is not able to properly identify the exact source and use of the cash activity within accounts when retail sales funds are commingled with check cashing/ATM/money service business (MSB) funds.
Check Cashing
- All cash supporting the check cashing activity must be withdrawn from this account.
- All cashed checks are required to be deposited into this check cashing account.
- In-Person or Online Transfer credits/debits to or from this account for operational purposes are NOT Permitted. Additionally, cash withdrawals from the separate designated account may NOT be used to make immediate cash deposits to another account.
- The $300 Check Cashing Monitoring Fee will be assessed on this account.
- Standard account fees will be assessed on this account as disclosed at account opening.
Money Service Businesses (MSB)
- All cash supporting the money service activity must be withdrawn from this account.
- All money service related funds or other related electronic credits must be deposited into this money service account.
- In-Person or Online Transfer credits/debits to or from this account for operational purposes are NOT Permitted. Additionally, cash withdrawals from the separate designated account may NOT be used to make immediate cash deposits to another account.
- The $300 Money Service Business Monitoring Fee will be assessed on this account.
- Standard account fees will be assessed on this account as disclosed at account opening.
Private ATM (PATMO)
- All cash supporting the ATM activity must be withdrawn from this account.
- All ATM electronic credits must be deposited into this PATMO account.
- In-Person or Online Transfer credits/debits to or from this account for operational purposes are NOT Permitted. Additionally, cash withdrawals from the separate designated account may NOT be used to make immediate cash deposits to another account.
- The $100 PATMO Monitoring Fee will be assessed on this account.
- Standard account fees will be assessed on this account as disclosed at account opening.
Retail Sales
- All retail sales proceeds and related business expenditures are required to be conducted through the designated account.
- Transactions not permitted include transfers to and from this account involving other CCB accounts designated for Check Cashing, Money Service Activities, or Private ATM Activities.
- Standard account fees will be assessed on this account as disclosed at account opening.