1. Audience: This document is intended for managers, directors and executives who deal with business
customer compliance and risk. In particular, this is intended for those who underwrite, board, or
monitor a portfolio of business customers will benefit from the contents of this white paper.
A Complete Approach to KYC with
Business Customer Intelligence
Prepared by:
Dan Frechtling, Chief Product Officer
Jodie Ruby, Director of Marketing
Steve Clendaniel, Director of Risk Consulting

2. Contents
Executive Summary.......................................................................................................................................1
The “Regulatory Olympics”...........................................................................................................................2
The Derisking Dilemma.................................................................................................................................3
Guidance Offered by Regulators...................................................................................................................3
Tools Currently in Use to Meet Regulatory Guidelines and Manage Risk....................................................5
What Common Risk Management Tools Miss..............................................................................................7
What is Business Customer Intelligence? .....................................................................................................8
Key Elements of Business Customer Intelligence ........................................................................................9
Ongoing Monitoring....................................................................................................................................11
How This Helps You Comply with Regulations and Avoid Reputational Damage ......................................12
G2’s Solutions for Commercial Banks.........................................................................................................13
About G2 Web Services ..............................................................................................................................13
Sources........................................................................................................................................................14

3. 1
Executive Summary
Anti-Money Laundering and Know-Your-Customer services form the fastest growing category of risk
spending globally, with a five-year CAGR surpassing 18%1
. With heightened regulatory uncertainty and
rising regulatory pressure, financial institutions need transparency into their business customer, Third-
Party Payment Processor and Third-Party Sender portfolios to better manage their risk. While existing
tools such as identity verification and transaction monitoring can help, they miss hidden risks that are
vital to effective due diligence and compliance programs. This whitepaper will explain these hidden
risks, and how business customer intelligence can help financial institutions comply with BSA and AML
regulations while maintaining and growing their sources of revenue.

4. 2
The “Regulatory Olympics”
The current regulatory landscape resulting from Operation Choke
Point in 2013 has led to increased pressure and scrutiny for financial
institutions that are scrambling to understand complex regulations
while maintaining and growing their businesses. Operation Choke
Point — an initiative launched by the US Department of Justice (DOJ)
in early 2013 — targeted financial institutions that had commercial
agreements with Third-Party Payment Processor (TPPP) and Third-
Party Sender (TPS) businesses that were deemed by the DOJ to have
a higher risk for money laundering and fraud. These businesses
include payment processors, payday lenders, debt consolidation
firms, adult entertainment companies and firearms dealers. Since
then, regulators have advised banks to take a risk-based approach in
assessing individual relationships rather than Choke Point’s
“derisking,” or declining services to entire categories of customers,
yet the effects of Choke Point’s derisking are still felt. Even before
Operation Choke Point, the creation of the CFPB by the Dodd-Frank
Act of 2010 not only added another regulatory body to the
landscape, it changed the dynamics of existing regulators. Like an
athletic team that has drafted a new player, the incumbents have
found themselves sometimes competing, sometimes collaborating.
The environment has been likened to the Olympics, where regulatory
bodies find themselves competing both together and against each
other for influence.
A recent research study conducted by G2 Web Services of risk and
compliance officers at mid to large-sized banks shed additional light
on the situation. One participant indicated that regulatory pressure
is unavoidable:
“This is the business we’ve chosen and these are the rules you must
follow in order to be able to stay in the game. If we want to
continue to grow and to prosper we have to get A’s on our report
card in terms of compliance. If we get anything less than that they
will shut down our growth. It’s not optional.”2
Glossary of Acronyms
AML: Anti-Money Laundering –
A set of procedures, laws or regulations
designed to stop the practice of
generating income through illegal
actions.
BSA: Bank Secrecy Act – Government
legislation created to prevent financial
institutions from being used as tools by
criminals to hide or launder money by
requiring banks to provide
documentation whenever clients deal
with transactions that involve large
sums of money.
CFPB: Consumer Financial
Protection Bureau – A regulatory
agency charged with overseeing
financial products and services that are
offered to consumers.
FFIEC: Federal Financial Institutions
Examinations Council – Formal
interagency body empowered to
prescribe uniform principles, standards,
report forms for federal examination,
and make recommendations to
promote uniformity in the supervision
of financial institutions.
FinCEN: Financial Crimes Enforcement
Network – A network administered by
the United States Department of the
Treasury whose goal it is to prevent and
punish criminals and criminal networks
that participate in money laundering.

5. 3
Another participant explained that changing regulations regarding
third-party relationships creates increased pressure:
“
In an ever changing regulatory environment, especially TPPP
being newer (the question) is, are the regulators going to
change their requirements? I think there’s a black hole in
banking, especially with examination, whereby examination
procedures and guidance say one thing, but we’re also held to
best standards and practices.”3
Despite the current environment where guidance can
sometimes be ambiguous, financial institutions are expected to
follow BSA and AML guidelines for KYC, both for direct customer
relationships as well as for Third-Party Payment Processors
(TPPPs) and Third-Party Senders (TPSs). The consequences for
failing to follow this guidance can be severe, and can affect any
size of financial institution. Headlines are full of cautionary tales
from banks in recent years that have fallen short in their Know
Your Customer (KYC) programs, some resulting in hefty fines
such as $4.9 million to CommerceWest and $1.2 million each to
Plaza Bank and Four Oaks Bank.
The Derisking Dilemma
As a result of Operation Choke Point, over 50 subpoenas were issued
to payment processors and the banks they do business with, creating
a shockwave through the industry4
. Fines have been and continue to
be issued as mentioned earlier. As a result, many financial institutions
have severed relationships with TPPPs and TPSs in an effort to reduce their risk and exposure to
regulator fines as a risk avoidance reaction. In doing so, these banks are cutting themselves off from
legitimate sources of revenue that can fuel business growth.
Guidance Offered by Regulators
To address this systematic derisking of TPPPs and TPSs, the OCC and FDIC promote a case-by-case
review of businesses by financial institutions, rather than eliminating entire categories from portfolios.
According to Barbara Hagenbaugh, deputy to the chairman for communications at the FDIC:
“… the Federal Deposit Insurance Corp. encourages supervised institutions to take a risk-based
approach in assessing customer relationships, rather than declining to provide banking services to
entire categories of customers without regard to the risks presented by an individual customer or
the financial institution's ability to manage the risk. That means that FDIC-supervised financial
institutions that properly manage customer relationships and effectively mitigate risks are neither
prohibited nor discouraged from providing services to any category of customer accounts or
individual customers operating in compliance with applicable laws.”5
KYC: Know Your Customer –
Regulations requiring banks
individually verify a client’s history,
risk, and financial position.
KYCC: Know Your Customer’s Customer
– banks requiring clients
to discover their client’s history,
thus gaining further insight into entire
hierarchy.
TPPP: Third-Party Payment Processor –
Bank customer that provides payment
services to customer and other
business entities; TPPPs often use
commercial bank accounts to conduct
payment processing for
their clients.
TPS: Third-Party Sender – A third-party
service provider considered a Third-
Party Sender when there is an
agreement with an ODFI or another
Third-Party Sender to originate
transactions and also has an
agreement with an originator to
initiate transactions into an ACH
Network on their behalf; a Third-Party
Sender is a subset of a TPPP.

6. 4
The FDIC, FFIEC, FinCEN, NACHA, and the OCC have all issued guidance for due diligence and ongoing
monitoring of business relationships to address BSA/AML requirements regarding relationships with
third parties, thus creating the added requirement to Know Your Customers’ Customer (KYCC). The
expectation is that financial institutions know all of their customers, regardless of whether they have a
direct relationship with them or if the relationship is through a third party. According to regulator
guidance, financial institutions need to know the risk profile of their customers, TPPPs and TPSs when
entering into these relationships, and also need review them on a regular basis to detect any changes
that could impact their business customer portfolio. In addition, the financial institution’s risk
assessments need to adjust to account for higher-risk customers so that the risk is properly managed:
FDIC FIL-127-2008:
 “Account relationships with entities that process payments for telemarketers and other merchant
clients could expose financial institutions to increased strategic, credit, compliance, transaction, and
reputation risks.
 Account relationships with these higher-risk entities require careful due diligence and monitoring as
well as prudent and effective underwriting.
 Payment processors pose greater money laundering and fraud risk if they do not have an effective
means of verifying their merchant clients' identities and business practices.
 A financial institution should assess its risk tolerance for this type of activity as part of its risk
management program and develop policies and procedures that address due diligence, underwriting,
and ongoing monitoring of high-risk payment processor relationships for suspicious activity.”6
FIN-2012-A010:
“Law enforcement has reported to FinCEN that recent increases in certain criminal activity have demonstrated
that Payment Processors present a risk to the payment system by making it vulnerable to money laundering,
identity theft, fraud schemes, and illicit transactions. Many Payment Processors provide legitimate payment
transactions for reputable merchant clients. The risk profile of such entities, however, can vary significantly
depending on the composition of their customer base. For example, Payment Processors providing consumer
transactions on behalf of telemarketing and Internet merchants may present a higher risk profile to a financial
institution than would other businesses. Telemarketing and Internet sales and RCC-related transactions tend to
have relatively higher incidences of consumer fraud or potentially illegal activities.”8
FFIEC BSA/AML Examination Manual
“The cornerstone of a strong BSA/AML compliance program is the adoption and implementation of
comprehensive CDD policies, procedures, and processes for all customers, particularly those that present a
higher risk for money laundering and terrorist financing. The objective of CDD should be to enable the bank to
predict with relative certainty the types of transactions in which a customer is likely to engage... The concept of
CDD begins with verifying the customer’s identity and assessing the risks associated with that customer.
Processes should also include enhanced CDD for higher-risk customers and ongoing due diligence of the
customer base.” 7

7. 5
With the increased amount of focus and scrutiny being placed on KYC – and more recently on KYCC –
many banks are being forced to allocate more resources managing regulatory requirements. A recent
study by McKinsey found that senior executives spend about 20 to 25 percent of their time on
regulatory matters11
.
Tools Currently in Use to Meet Regulatory Guidelines and
Manage Risk
In the research study conducted by G2 Web Services quoted earlier, one participant described one of
the key challenges of risk management as a “constant evolution of bad guys getting more sophisticated
at a faster rate than we are.” In today’s environment of uncertainty, how are financial institutions
managing the onboarding and ongoing monitoring of business customer, TPPP and TPS relationships?
This same study revealed that banks are using the following types of solutions or processes:
We will explore these solutions in more detail here, including their advantages and disadvantages:
OCC 2006-39:
“Banks that engage in ACH transactions with high-risk originators or that involve third-party senders face
increased reputation, credit, transaction, and compliance risks. High-risk originators include companies
engaged in potentially illegal activities or that have an unusually high volume of unauthorized returns. High-risk
originators often initiate transactions through third-party senders because they have difficulty establishing a
relationship directly with a bank.
Before a bank engages in high-risk ACH activities, the board of directors should consider carefully the risks
associated with these activities, particularly the increased reputation, compliance, transaction, and credit risks.
The board should provide clear direction to management on whether, or to what extent, the bank may engage
in such ACH activities.”10
Onboarding
- Identity Verification
- Manual Credit and Asset Searches
Ongoing Monitoring
- Transaction Monitoring
- Manual Spot Checks
NACHA Third Party Senders and the ACH Network (2nd Edition)
“Due diligence is key to mitigating risk when engaging in a banking relationship with a Third Party. Procedures
should include gathering and evaluating information and relevant documentation about the Third Party.
Enhanced due diligence procedures should include:
 Background checks on the Third Party and its principals using independent public databases
 Background checks on a representative sample of the Third Party's clients
 Review of the Third Party's website
 Internet research and website review of a representative sampling of Third Party's clients.”9

8. 6
Identity Verification
The benefits of Identity verification solutions include:
 Compliance with core BSA/AML guidance for due diligence and enhanced due diligence (EDD)
 Compliance with the CIP rule of the Patriot Act
 Visibility into the identity of the individual completing the application, including the ability to
flag invalid social security numbers
Overall, using identity verification is a good standard practice for effective KYC programs. However,
there are some gaps in these solutions:
 They are most effective when the information being disclosed can be verified
 The solution is only as good as the database that is being used to verify the information
 Fraudsters are able to outmaneuver identity verification applications in a number of ways
 Fraudsters may also prey on certain banks that only perform cursory investigations
So, while regulators acknowledge identity verification as a necessary component for KYC, it has some
limitations that demonstrate the need for other tools.
Manual Credit and Asset Searches
The benefits of credit and asset search tools include:
 Consolidation of many data sources to determine the financial health of a prospective business
customer during onboarding, allowing the financial institution to access a variety of data points
to evaluate a potential business customer
 High regard from regulators since the underlying data comes from what they consider to be
credible sources
 Ease of performing and integrating these searches into existing onboarding processes
While these searches are valuable and provide helpful information regarding the financial health of a
prospective business customer, there are several shortcomings to these tools:
 While the information gathered by these data sources provides details on principals, it may lack
business customer historical information which can reveal important details about the
prospective business customer’s risk profile
 Since analysts are needed to review the outputs of these searches and analyst experience can
vary from person to person, the outcome of these reviews can be spotty
 Such searches are not easily quantifiable, making the process difficult to repeat.
Transaction Monitoring
Transaction monitoring solutions have several benefits including:
 Compliance with key regulations including OCC’s CFR 21.11 & 2013-29, and FDIC’s FIL 44-2008
& FIL 3-2012
 The ability to detect behavior indicative of some fraud and money laundering activities

9. 7
 Data science capabilities that allow quicker detection of anomalies
 Alerts that can provide evidence of suspicious activity or outright fraud
 The ability to separate suspicious transactions from normal transactions for further review
Clearly, transaction monitoring solutions play an important role in a financial institution’s KYC program.
However, they do fall short in a few areas:
 They are most effective after fraud has struck
 They miss leading indicators of fraud that can provide a more complete risk profile of the
business customer
 These solutions are vulnerable to fraudsters who can split their transactions (aka load balancing)
across several banks in an attempt to outsmart banks’ systems
Manual Spot Checks
Manual spot checks are commonly used in the ongoing monitoring of a bank’s business customer
portfolio and are useful in the following ways:
 These processes are easy to start and modify – particularly if the number of business customers
being reviewed is low
 The reports are simple to explain to auditors since they do not involve many technical processes
Despite the simplicity of the processes and reporting, there are several complexities in utilizing manual
spot checks.
 It is more difficult to detect the nuanced changes than can take place in a customer’s business
that could raise its risk profile and trigger a more in-depth review
 Manual processes take more time and additional employee resources
 There is no automated scoring associated with these checks, which slows the
monitoring process
The solutions described above all have benefits to KYC programs. At the same time, they miss vital
aspects of KYC which need to be considered for a robust program that helps banks reduce their
regulatory burden, decrease uncertainty, and make faster onboarding decisions.
What Common Risk Management Tools Miss
One main type of risk that the tools described above miss is hidden customer risk. This includes direct
evidence of illegal activity, past indicators of fraud, and compliance violations. It also includes links to
illicit customers, criminal fraud rings and hidden websites, all of which can drastically change the
business’s risk profile. Additionally, these tools miss a business customer’s use of multiple financial
institutions, which could also indicate a higher degree of risk.
The second main area that these tools miss is automation, namely scoring, which turns the above risk
indicators into actionable numbers that can greatly improve the speed of onboarding decisions. The
ideal score is based on a combination of past business customer history as described above, but also

10. 8
uses data science to predict the likelihood of future fraud and compliance violations. Automated scoring
leverages technology to greatly improve onboarding and ongoing monitoring processes.
What is Business Customer Intelligence?
Business customer intelligence provides a wealth of information that commonly used risk management
solutions miss. In this case, “customer” refers to business customers of a financial institution. While
identity verification provides knowledge of the risk profile of the individual applying to become a
business customer of a financial institution, business customer intelligence provides foreknowledge
based on the customer’s prior actions. And while transaction monitoring provides sight into past
transaction activities, it lacks the foresight to predict the likelihood that fraud or compliance violations
will occur, which is where business customer intelligence plays a powerful role.
Business customer intelligence combines a large historical dataset of business information, industry
expertise, and data science to give financial institutions a comprehensive view of the risk associated
with a business. This dataset, known as the Business Data Map, combines over ten years of business
customer data collected through partnerships with acquiring banks and card networks with 3rd
party
data sources such as watch lists and high risk business categories. This powerful database is then used to
predict future business customer violations through data science, critical information needed during
customer onboarding. This database is constantly updated and expanded as millions of business
customers are scanned and evaluated monthly, allowing financial institutions to receive alerts when
changes in their portfolio occur as a result of fraud, reputation changes, or other reasons that indicate a
changing risk profile. The bottom row in Figure 1 illustrates the functionality in current solutions for
onboarding and ongoing monitoring. Business customer intelligence leverages this functionality and
combines it with leading indicators listed in the top row of Figure 1 to generate the highest utility for risk
management programs.
Figure 1
Business Customer Intelligence

11. 9
Key Elements of
Business Customer Intelligence
1. Business customer intelligence finds hidden connections: Years of
historical business customer data backed by data science to find links
between customers gives financial institutions a much deeper
understanding of the risk profile of any customer they are trying to
onboard. Figure 2 shows a random sample of this database with
websites that have had content violations in the past. Each purple dot
represents a violating website and each green dot represents a business
customer that has sold its products through that website.
In the bottom left the green “flower” shows many business customers selling
illegal products through the same website (figure 2a). Using this intelligence, a
financial institution could decline a new application from a business customer
engaged in this activity.
By contrast, the business customer in Figure 2b has been using different
websites to sell prohibited products. The next time an application from this
business customer comes through using a new website, the financial
institution can use this information to reject the business customer.
Finally the business customer in Figure 2c seems to be directly related only to
one violating site. However, graph analytics determines that he is potentially
connected to a large cybercriminal operation. These examples illustrate the
power of historical business customer risk information and how it can impact
important onboarding decisions.
2. Business customer intelligence enables predictive modeling: An extensive database of
historical and current data, combined with 3rd
party data sources, can be a powerful tool used
for predictive modeling of key business customer behaviors. Knowledge of these behaviors
helps financial institutions obtain a more robust risk profile at onboarding. Examples include
hidden connections to undisclosed online businesses, past fraud and content violations, and
connections between individuals and businesses. Examples of 3rd
party data sources are
blacklists (PEP, OFAC, NABP, etc.) and whitelists (MPAA, NABP, etc.). Data Science takes all of
these sources and then predicts the likelihood that the business customer will exhibit risky
behaviors in the future such as committing compliance violations or fraud. Figure 3 illustrates
the power of this predictive capability. A UK Bank was able to limit fraud to 2% of the average
loss by using customer business intelligence based on historical data:
Figure 2a
Figure 2c
Figure 2b
Figure 2

12. 10
3. Business customer
intelligence can yield
instant quantification: The
large dataset described
above comes to life with an instant score that allows financial institutions to clear low risk
business customers who score “green”, decline high risk business customers who score “red”,
and perform deeper investigations
on business customers who score “yellow” (Figure 4). With reason codes explaining how the
score was calculated, a financial institution can see what is driving the score and can make
decisions to clear the business customer or not, based on its risk tolerance. There are important
advantages to using this solution for business customer onboarding. First, it greatly decreases
onboarding time, in some cases up to 93%12
. Second, it can be integrated via APIs into home
grown or third party vendor platforms, enhancing existing processes. Finally, financial
institutions can choose to get up and running more quickly by accessing a portal to generate risk
profiles on prospective business customers. Ultimately this allows financial institutions to make
their processes repeatable, scalable and easier to explain to auditors and examiners.
4. Business customer intelligence powers a risk-based approach: With the depth of information
that business customer intelligence provides – and the ability to obtain instant scores on
prospective business customers – financial institutions can much more realistically adopt a risk-
based approach to business customers, TPPP and TPS portfolio management. Rather than ruling
out entire categories of business customers, the use of scoring system – with powerful data and
data science behind that score – allows a financial institution to review each business customer
on a case-by-case basis and avoid losing potentially lucrative relationships. This can also be
achieved with TPPP and TPS relationships, particularly if the financial institution implements a
KYCC program requiring business customer registration by the TPPP or TPS. As seen in the case
study outlined below in Figure 5, a financial institution that was under an MRA (Matter
Requiring Attention) from the OCC for inadequate KYC/KYCC policies was able to clear the MRA
by establishing a formal TPPP management program by flagging high risk business customers.
Figure 3: Limiting Fraud Case Study
£655
(2%)
Average
Losses:
£33,000
Merchant X Losses Average Losses
Limited Fraud Loss
G2 Compass Score™
Figure 4
Figure 5: Example of Establishing a Risk-Based Approach to KYC

13. 11
5. Business customer intelligence can be richly reported: Another powerful capability of business
customer intelligence is that it can be used to create rich, actionable reports and dashboards.
Some examples of these reports, such as those shown in Figure 3, include 1) a quick snapshot of
a financial institution’s risk categories in its portfolio, 2) benchmarking data to understand how a
financial institution’s portfolio categories compare with the broader industry, and 3) reports
that show which categories are being cleared more often versus boarded, allowing the financial
institution to better understand its onboarding process. This reporting can help to uncover new
opportunities to fuel business growth.
Ongoing Monitoring
Business customer intelligence is also used in the ongoing monitoring of a financial institution’s business
customer portfolio. Ongoing monitoring is a critical role in risk management, as changes that occur in a
business customer’s profile after onboarding could have a damaging effect on the financial institution’s
portfolio. Businesses known as “shelf” companies or pseudo-legitimate sleeper companies may be
formed with the intent to commit future fraud. This may occur as “bust-out” fraud by patient criminals
or the future sale of the front company to a criminal entity. As mentioned earlier in this whitepaper,
regulators have issued guidance around the ongoing monitoring of business customers for thorough KYC
programs. Some examples of areas that should be monitored include:
Figure 6:
Example dashboard
and report center

14. 12
1. Business Monitoring: After a business customer has been onboarded by a financial institution,
it is very important to perform a periodic review of that customer’s business to ensure there
haven’t been any material changes. Changes that could also lead to problems for the financial
institution include changes in business classification, the sale of high risk goods or services,
deceptive marketing practices, and changes in business models. A monitoring solution that
detects and reports changes in these areas helps financial institutions identify these customers
and take actions consistent with its risk profile.
2. Reputation: A negative change in business reputation is a leading indicator of a business
customer’s potential liability to a financial institution. Many fines that have been issued recently
could have been avoided if reputation monitoring had been incorporated into periodic portfolio
reviews.
3. Fraud: Fraud monitoring and alerts can also help to weed out potentially harmful business
customers from a financial institution’s portfolio. Financial institutions benefit from the network
effect of information reported by their peers, which is used to notify them should they enter
into a relationship with a business with a history or high likelihood of fraud.
Ongoing monitoring provides financial institutions with continuous protection against individuals and
businesses who are actively trying to defraud the system. In addition, it provides a more proactive way
for financial institutions to manage both positive and negative risk.
How This Helps You Comply with Regulations and Avoid
Reputational Damage
As outlined at the beginning of this whitepaper, there are several regulatory bodies that have issued
guidance for the onboarding and ongoing monitoring of business customers, both direct customers and
those underneath a TPPP or TPS. Business customer intelligence enables a financial institution to take a
risk-based approach to managing these relationships. With a thorough onboarding process that includes
the ability to score a business customer’s risk profile based on its past history of fraud and compliance
violations, as well as any connections to hidden businesses it may not have disclosed, the financial
institution is able to make better onboarding decisions based on its risk tolerance. It is also able to have
greater visibility into the portfolios of its TPPPs or TPSs. Similarly, establishing regular portfolio
monitoring to detect changes in business practices, reputation or fraud gives banks the ability to make
proactive decisions about their customer relationships. Integrating these tools into their existing due
diligence and compliance processes gives banks the information they need to make decisions that
ultimately help them comply with regulations, while providing them with robust reports for auditors and
examiners. According to many bankers, regulatory risk is considered to be the single largest risk they
face – even beyond cybersecurity risk and fraud risk. A comprehensive due diligence and ongoing
monitoring program for business customers and third parties is paramount for effectively managing
this risk.
In addition to managing regulatory requirements, business customer intelligence helps banks avoid
reputational damage which closely follows regulatory risk in terms of importance to financial
institutions. Implementing a comprehensive KYC program that is in balance with the level of risk the
bank is taking on will significantly help in lessening this risk category.

15. 13
G2’s Solutions for Commercial Banks
G2’s Solutions for Commercial Banks, comprised of G2 KYC Investigate and G2 KYC Protect, allow
financial institutions to create a risk-based approach to managing business customers, TPPP and TPS
portfolios with proactive due diligence and business monitoring solutions. This includes:
 Unique transparency based on the G2 Business Data Map – the most extensive database of
business customer risk and fraud history available, developed by G2 Web Services in
partnership with major US card networks and global acquiring banks
 An instant assessment from the G2 Compass Score®, which predicts the likelihood of fraud
or compliance violations with 99% accuracy
 Ongoing business customer monitoring, including changes in business classification, high
risk goods and services, business models, fraud alerts and reputation changes in your
portfolio
G2 KYC Investigate conducts extensive due diligence on business customers, TPPPs and TPSs prior to
boarding, while G2 KYC Protect monitors business customers, TPPPs’ and TPSs’ for risk and fraud
indicators. With G2’s Solutions for Commercial Banks, financial institutions can identify past risky
behavior, leading indicators for future violations, and receive ongoing alerts when changes in their
portfolio occur.
About G2 Web Services
G2 Web Services is a leading global provider of business customer risk management solutions, including
due diligence, compliance and fraud protection. G2 Web Services helps acquirers, commercial banks and
other payment providers take on the appropriate level of risk in their business customer portfolios,
while protecting against brand damage, illegal activity and noncompliance assessments.
Contact us to learn more about how our Solutions for Commercial Banks can help your business:
kyc@g2llc.com

16. 14
Sources
1. http://www.marketwatch.com/story/2014-spend-on-credit-fraud-risk-compliance-data-topped-
usd19-billion-up-621---burton-taylor-2015-06-11
2. G2 Banking Research Study, March 2015
3. G2 Banking Research Study, March 2015
4. http://dealbook.nytimes.com/2014/01/26/justice-dept-inquiry-takes-aim-at-banks-business-
with-payday-lenders/?_r=0
5. http://www.americanbanker.com/bankthink/fdic-responds-banks-must-manage-client-risk-on-
case-by-case-basis-1073979-1.html
6. https://www.fdic.gov/news/news/financial/2008/fil08127.html
7. https://www.ffiec.gov/bsa_aml_infobase/documents/BSA_AML_Man_2014_v2.pdf
8. http://www.fincen.gov/statutes_regs/guidance/html/FIN-2012-A010.html
9. NACHA Third Party Senders and the ACH Network (2nd Edition)
10. http://www.occ.gov/news-issuances/bulletins/2006/bulletin-2006-39.html
11. http://www.bankdirector.com/issues/regulation/year-in-review-big-profits-but-big-regulatory-
fines-too/
12. Link to compass case study

17. G2 Web Services, LLC