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#1094024 - 12/09/08 03:05 PM BSA AML and Mobile Banking
Compliance Heifa Offline
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Joined: Sep 2001
Posts: 182
Up on the Roof in Texas
We are starting to offer Mobile Banking that mirrors the functions of our internet banking site. The customer may NOT open new accounts but can transfer funds and use bill pay. I am trying to determine if there are any BSA AML risk with this product and cannot find anything in the exam manual. Any thoughts?

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#1094044 - 12/09/08 03:25 PM Re: BSA AML and Mobile Banking Compliance Heifa
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
Since you're designing the product to act like your internet banking site, start by assuming the same risks that you assessed in connect with the internet product. In fact, it may be appropriate for you to combine internet and mobile banking products under a single set of risk assessments, with minor tweaks here and there to account for whatever is unique about one product or the other.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

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