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Know Your Portfolio with Ongoing Monitoring

02.03.2021

Any financial institution looking to start a cannabis banking program should first review their due diligence (or know-your-customer) programs. Many existing CRB programs across the country succeed by partnering with their state or local governments and their BSA (or compliance) teams to provide the highest level of transparency, but not without the legwork of establishing reliable procedures.

While the initial steps of any compliance program start with preliminary customer due diligence, many times, consistent, ongoing monitoring falls by the wayside because it can be overly time-consuming.

Customer Due Diligence (CDD)

The processes and procedures established to understand the nature of each customer relationship to detect and report unusual or suspicious activity. CDD policies document clear job duties and standards for obtaining and retaining information during initial onboarding.

Enhanced Due Diligence (EDD)

Follows an already established Customer Due Diligence program but with heightened documentation and data requirements from high-risk customers that pose a higher money laundering or terrorist financing risk (thus a higher risk exposure to the financial institution).

Ongoing Monitoring

A component of CDD or EDD programs. Maintaining and updating customer information, including corporate structure, beneficiary or ownership changes, and identifying and reporting any suspicious transactions for updated risk analysis on a defined schedule. Other common components of ongoing monitoring steps include:

  • Regular onsite visits
  • Negative or adverse media checks
  • Customer Vendor validations*
  • Advertised pricing versus sales receipts*
  • Transaction Reviews*
  • Inventory Reviews*

*The NCS Platform has features that support this policy

These programs must go further with CRB (cannabis-related business) portfolios due to their inherent risk. While ongoing monitoring can be time-consuming, with the NCS Platform, most of its components are available immediately without having to wait for your customer to provide documentation.

About the Author Paige Reimers

Paige Reimers is the Chief Operations Officer of NCS Analytics, where she leads the company’s operations, product implementation, customer success, marketing, security, and strategic growth initiatives. Since joining NCS in 2016, Paige has been instrumental in transforming the organization from a regulatory data provider into a leading SaaS analytics company serving financial institutions and regulators nationwide. Throughout her tenure, she has advanced through multiple executive leadership roles, including Vice President of Operations and Senior Vice President of Operations, before being named COO, reflecting her significant contributions to the company’s growth and success.

At NCS Analytics, Paige has overseen the development and launch of several innovative SaaS solutions, including NCS Thea, the industry’s first government-mandated cannabis lending intelligence platform. She has led cross-functional teams responsible for product implementation, customer support, operations, marketing, and strategic vendor management, helping organizations leverage trusted data to improve underwriting, portfolio monitoring, compliance, and risk management. Her leadership has also been instrumental in establishing scalable customer onboarding programs, building high-performing support and implementation teams, and driving product adoption across the financial services industry.

Paige has also played a critical role in strengthening NCS Analytics’ operational foundation. She developed comprehensive operational, cybersecurity, and risk management policies, established disaster recovery and business continuity programs, and helped the company maintain SOC compliance for multiple consecutive years. Her focus on operational excellence, governance, and customer experience has enabled NCS to scale while maintaining the trust and confidence of its customers.

Before joining NCS Analytics, Paige built a strong foundation in banking and financial services with leadership roles at consumer and commercial banks. There, she managed branch operations, risk management, regulatory compliance, and employee development while working closely with clients to identify financial solutions. Her experience overseeing operational controls, internal audits, and regulatory requirements provides valuable insight into the challenges financial institutions face when evaluating and managing risk.

Today, Paige continues to lead NCS Analytics’ strategic operations while helping shape the company’s long-term vision. She is passionate about building scalable organizations, developing innovative technology solutions, and delivering actionable intelligence that brings greater transparency to the cannabis industry. Her unique blend of banking expertise, operational leadership, and technology experience has positioned her as a driving force behind NCS Analytics’ mission to empower lenders, regulators, and cannabis businesses with trusted, data-driven decision-making.

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