Two recent issuances from one of Protiviti's 2017 publications, one an update to the Financial Crimes Enforcement Network’s (FinCEN) Customer Due Diligence (CDD) FAQs and the other a publication by The Wolfsberg Group (Wolfsberg) titled ‘‘FAQs on Source of Wealth and Source of Funds,’’ reinforce the importance of developing and implementing risk-based Know Your Customer (KYC) standards.

This article identifies what questions AML compliance officers and their senior management should be asking as they consider these two publications.