Each group designates the level of risk a customer poses, based on exhibiting operational gaps or other factors that (in each case) regulators discuss in RDC, AML, or fraud risk management.  The gaps are risk weighted according to their prominence in the regulatory guidance or examination manuals, prudential considerations, expert input, and industry feedback.  Most customers end up between 2 and 3, then 4. 

  • Group 1: Minimal to low risk
  • Group 2: Low to moderate risk
  • Group 3: Moderate risk
  • Group 4: Higher risk
  • Group 5: Warrants prompt attention, possibly including disabling the service