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Elder Financial Exploitation – Banking Standards & Risk Review

Risk-Based Customer Due Diligence (CDD / KYC)

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Assessment of how financial institutions establish and maintain customer understanding, including account purpose, expected activity, and risk profiles consistent with industry standards.

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Transaction Monitoring & AML/BSA Controls

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Review of transaction activity, monitoring systems, and operational processes intended to identify unusual or potentially suspicious activity, including large wire transfers or pattern changes.

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Escalation, Documentation & Internal Controls

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Evaluation of whether concerns were recognized, documented, and escalated through appropriate compliance, fraud, or risk-management channels.

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Regulatory Guidance & Industry Practice

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Analysis informed by accepted banking practices and regulatory frameworks, including AML/BSA expectations by regulators, customer due diligence standards, and supervisory guidance relating to vulnerable customer protections.

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Typical Expert Witness Engagement Scope

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  • Review of account history and transaction patterns

  • Analysis of bank policies, procedures, and internal controls

  • Evaluation of operational decision-making and escalation processes

  • Comparison of institutional practices with generally accepted banking standards

 

Opinions are based on records and facts specific to each engagement and are limited to banking operations, regulatory context, and industry practice. No legal conclusions are offered.

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Practical Banking Perspective

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With more than 40 years of banking leadership experience — including lending, compliance oversight, operational risk, and AML monitoring environments — my analysis reflects how decisions are made within real-world financial institutions.

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Related Expertise

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Bank Governance & Internal Controls

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Independent, Neutral Analysis for Litigation Support

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Services are provided on a neutral, independent basis for plaintiff or defense counsel, helping the court understand banking operations, regulatory expectations, and institutional decision-making within the context of alleged elder financial exploitation. This page is intended for attorneys, institutions, and parties seeking independent analysis of banking operations and industry practices in litigation matters. This information is provided for general educational purposes only and does not constitute legal advice or an opinion regarding any specific matter or set of facts.

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