Concentration Accounts

  • Also known as special use, omnibus, settlement, suspense, intraday, sweep or collection accounts. They are internal accounts used to assist with the settlement and processing of customer transactions, often in conjunction with private banking, trust and custody accounts, funds transfers.

  • They pose an AML threat if the customer identifying information is lost when the account is used, this loses the audit trail. Good practices include:

  • Require dual signatures on all general ledger entries

  • Prevent direct customer access to concentration accounts

  • Capture information in customer statements

  • Prevent customer knowledge of concentration accounts

  • Reconcile the accounts frequently, ensure segregation between the reconcilement and those that use the accounts on a day-to-day basis

  • Resolve discrepancies timely

  • Monitor for recurring customer names

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