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1. In response to the Q&A “Remote Deposit Capture:”

   Customer Due Dilgience and transaction monitoring is a key to risk mitigation. You may want to ensure that your customer is only depositing checks made payable to your customer. This is a good way to keep out most of the Money Services Business activity. In your customer agreement you can also prohibit foreign checks and restrict the deposit of third-party checks. Since administrative controls such as the agreement can easily be circumvented, additional controls are warranted, such as looking at the check images. At all cost, you want to prevent your customer from depositing a neighboring business’s checks.

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