Business onboarding, EDD and fraud queue review for banks and credit unions

Sweat AI is an AI-native BPO for banks and fintechs. For community banks, credit unions and sponsor banks, we start with business onboarding and fraud reviews. We work business account applications, enhanced due diligence and periodic reviews, and fraud and monitoring alerts 24/7, under your policy, and hand back each case with the evidence and a recommendation. Your BSA officer and your team decide.

The same rules, a smaller team

The beneficial ownership rule applies to covered financial institutions, a term that includes banks required to have an AML program under the Federal Deposit Insurance Act and the Federal Credit Union Act (31 CFR 1010.605, 31 CFR 1010.230). A community bank or credit union opening a business account runs the same ownership and control tests as a large bank, with a fraction of the staff.

The pressure points are familiar:

• Business account applications with holding-company owners, out-of-state entities or unclear business models that sit in the queue until someone has an afternoon free.
• EDD reviews for higher-risk customers that were due last quarter.
• Periodic reviews that come due in batches.
• Alert queues that grow faster than the BSA team.
• One or two people who know how everything works, and a queue that stops when they are on leave.

What we review

Business account onboarding

• The entity: registration, status, formation date and addresses, against the application.
• Ownership and control: every individual owning 25 percent or more of equity interests, directly or indirectly, and a single individual with significant responsibility to control or manage the business, traced through holding companies (31 CFR 1010.230). If your policy uses a lower threshold, we use yours.
• Screening of the entity and its people, with potential matches resolved using identifiers.
• The nature and purpose of the relationship: what the business does, how it will use the account and whether its public footprint supports that.
• Documents, checked for entity match, date and what each can establish.

Enhanced due diligence and periodic review

Bank AML programs must include risk-based procedures for ongoing customer due diligence: understanding the nature and purpose of customer relationships to build a customer risk profile, and ongoing monitoring to report suspicious transactions and, on a risk basis, to maintain and update customer information, including beneficial ownership (31 CFR 1020.210).

For EDD and periodic reviews we refresh the ownership and profile, re-screen, look at adverse media and litigation in the public record, compare actual activity with the stated purpose where you share it, and recommend whether the risk rating should change. Backlogs are worked in the order you set, for example highest risk first.

Fraud and monitoring alerts

We triage and investigate transaction-monitoring and fraud alerts, including account-takeover and money mule signals, and write each one up for your decision. Timing matters: a bank must file a suspicious activity report no later than 30 calendar days after initial detection of facts that may constitute a basis for filing (31 CFR 1020.320), so an alert that waits a week has used a week. Details are on fraud and alert review.

For sponsor banks

A sponsor bank is responsible for customers onboarded through its fintech partners. The federal banking agencies noted in their 2024 request for information that risks may be heightened where the fintech performs key functions such as "performing customer identification and due diligence" and "monitoring transactions" (89 FR 61577).

We can work business onboarding and review cases under your program's policy, whether applications come to you directly or through partners, and give each case a record your team can check. Fintech partners can work with us under your program too; see neobanks and BaaS.

Working with us as a third party

We are a third party to you, and the agencies' guidance is clear that "a banking organization's use of third parties does not diminish its responsibility" to meet its obligations "to the same extent as if its activities were performed by the banking organization in-house" (Interagency Guidance, 2023). We make oversight practical:

• We work to your written policy and escalation rules, and flag cases that fall outside them.
• Every finding carries its source excerpt, capture time and limitation, so your team can check any case.
• We document gaps openly, and we never mark a missing check as passed.
• Decisions, reporting and customer actions stay with you.

For due diligence questions about security and data handling, talk to us directly.

Coverage

We work 24/7, including weekends and holidays, so the queue is done when your team logs in, and urgent cases go to your named contact immediately. See 24/7 onboarding review.

What stays with you

Account decisions, risk ratings, EDD conclusions, SAR decisions and filings, restrictions and closures, and customer communication, unless you authorize us to prepare it. We recommend; you decide.

Talk to us

Tell us where your queue is longest: business accounts, EDD, periodic reviews or alerts. We will show you how we would work your next batch and what your team would receive. The illustrative sample KYB review shows the format.