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Certain kinds of businesses may require enhanced customer due diligence at account opening and ongoing transaction review. Banks should conduct a risk assessment and ensure that controls are proportionate to the customer’s risk level. The following should be considered when doing business with high-risk customers: their anti-money laundering systems; potential for being abused by money launderers; their level of risk; and the bank’s ability to control that risk. Entities that traditionally have been identified as high-risk include:

• Nonbank Financial Institutions (NBFI), including Money Service Businesses -Typical examples include security brokers and dealers, check-cashing services, currency dealers and exchangers, and issuers, sellers, or redeemers of traveler’s checks, money orders, or stored value cards. Card clubs, gambling casinos, and money transmitters are also NBFIs.

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