I have been participating in BSA Compliance training and again have been reminded of how much front line staff can help determine suspicious activity. The BSA program is enterprise wide and not just the responsibility of the BSA officer. This is where training for staff is so important. Reports reviewed from systems are great and will help to identify patterns and large dollar activity, but staff’s knowledge of the customer/member base is invaluable.
Here is an example that a BSA officer I spoke with recently experienced in their financial institution:
Reports generated by the BSA monitoring system reflect multiple, large dollar (between $2,000 and $9,000) transactions to a personal account over a 3 month period. The account has been open and active for 5 years. Historically, the account did not have cash deposits. I admit, this looks and sounds very suspicious; until branch personnel were questioned.
The tellers at the branch knew that Grandma had passed away and her house was full of antiques. In fact, some of the branch personnel had purchased antiques from her son, the account holder. The antiques were sold at various auctions and private sales. Buyers pay in cash. The activity that looks very suspicious in reports can be fully explained by the branch personnel.
This had a happy ending, and the situation was innocuous, but what if it wasn’t?