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January 6, 2015
Business Accounts Documentation and Procedures with Beneficial Ownership
Deborah Crawford

January 6, 2015
FFIEC Cybersecurity Initiatives and Observations from the 2014 Assessments
Susan Orr

January 15, 2015
The ABC's of IRAs - The Basic Ingredients
Patrice Konarik

January 20, 2015
B & Z Appraisal Rules - Getting Them Right
Jack Holzknecht

January 21, 2015
HMDA Soup to Nuts
David Dickinson

January 22, 2015
Navigating the Treacherous Waters of IRA Rollovers, Transfers and Beneficiary Payouts
Patrice Konarik

January 28, 2015
Mortgage Life Cycle
Part I
David Dickinson and Jerod Moyer



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#1602597 - 09/12/11 05:07 PM Risk Rating Question - Identifying HIFCA & HIDTA
Newly Southerner Offline
100 Club

Registered: 06/09/11
Posts: 170
I got the risk rating form deposit and commercial accounts from bankers tools.

on the sheet it states

Principal office located in HIFCA/HIDTA
(High Risk Money Laundering and Related Financial Crime Area)
High Intensity Drug Trafficking Area)

How and where can I find out if the business is located in such area? Is there a website or some sort of guide that we can reference to determine whether or not if the business is located in a HIFCA or HIDTA?

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BSA/AML/CIP/OFAC
#1602612 - 09/12/11 05:43 PM Re: Risk Rating Question [Re: Newly Southerner]
Doug Hendrickson Online
Power Poster

Registered: 10/01/09
Posts: 3426
Loc: NE New Mexico
HIDTA counties by state can be found on:

http://www.nhac.org/

I thought there was a map on the Office of the National Drug Control Policy, but I can't find it.

This is what I have on HIFCA:

http://www.fincen.gov/law_enforcement/hifca/index.html

I'd also appreciate any and all information about where more 'improved' maps can be found.

Also, is anyone aware of any 3rd party bsa/aml products that might read zip codes on your CIF and note if it's in a HIDTA or HIFCA?


Edited by Doug Hendrickson (09/12/11 05:46 PM)
_________________________
I hear and I forget. I see and I remember. I do and I understand.--Confucius

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#1602664 - 09/13/11 05:47 AM Re: Risk Rating Question [Re: Newly Southerner]
Ken_Pegasus Offline
10K Club

Registered: 08/30/01
Posts: 17576
Loc: Another trip around the sun
As Doug suggests, there was a servicable HIDTA map, but they appear to have reorganized the ONDCP web site and I cannot find it either.

You can use the Census Bureau to identify the county where the zip code is located. Then you can go to a U.S. map where you can click on the state and it will take to you information that lists the HIDTA counties in that state. (The previous ONDCP map was far more functional.)

With FinCEN's IT modernization program use of a zip code on a BSA form will automatically identify the county and any HIFCA or HIDTA status.

While neither of these observations actually meet your needs, that latter suggests that someone has built or is building a data base where zip code queries will identify HIDTA or HIFCA counties. We will hope they make it accessible to the public.
_________________________
"Oh God, thy sea is so great and my boat is so small." Breton fisherman's prayer in JFK's office.

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#1602679 - 09/13/11 08:32 AM Re: Risk Rating Question [Re: Doug Hendrickson]
BSABecky Offline
100 Club

Registered: 03/18/11
Posts: 126
Loc: Seymour, IN USA
Doug, Jack Henry's Yellow Hammer BSA takes our zipcodes into account and gives a score based on HIDTA counties. It doesn't necessarily make a client high risk, but it can lead that direction. Is this what you mean?
_________________________
My opinions do not necessarily reflect those of my employer.

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#1602728 - 09/13/11 09:41 AM Re: Risk Rating Question [Re: BSABecky]
Doug Hendrickson Online
Power Poster

Registered: 10/01/09
Posts: 3426
Loc: NE New Mexico
Yes, thank you.
_________________________
I hear and I forget. I see and I remember. I do and I understand.--Confucius

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#1607658 - 09/23/11 09:17 AM Re: Risk Rating Question-Identifying HIFCA & HIDTA [Re: Doug Hendrickson]
Ken_Pegasus Offline
10K Club

Registered: 08/30/01
Posts: 17576
Loc: Another trip around the sun
#1 BOL Users: What DP or AML vendors in addition to Jack Henry automatically identify HIFCA or HIDTA status based on the use of zip codes?

#2 BOL Users: If there was a place where you could type in a zip code and it would automatically indicate its presence in a HIFCA or HIDTA how would you use it?
_________________________
"Oh God, thy sea is so great and my boat is so small." Breton fisherman's prayer in JFK's office.

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#1607697 - 09/23/11 09:54 AM Re: Risk Rating Question-Identifying HIFCA & HIDTA [Re: Ken_Pegasus]
Doug Hendrickson Online
Power Poster

Registered: 10/01/09
Posts: 3426
Loc: NE New Mexico
#2: I would use it in the BSA/AML/OFAC risk assessment. The majority of our customers are in-state and the cities are recognizable to counties which might be HIDTA or HIFCA. However, we have a number of out-of-state accounts and it would be helpful to be able to plug in the zip to see if they are in a HIDTA/HIFCA and what impact that might have on the risk assessment. We're converting to a new core processor next year and I'm also hoping to install something like BAM or Patriot Officer that might do that on a more automated basis (don't know if they do).
_________________________
I hear and I forget. I see and I remember. I do and I understand.--Confucius

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#1607720 - 09/23/11 10:12 AM Re: Risk Rating Question-Identifying HIFCA & HIDTA [Re: Ken_Pegasus]
Deena Offline
Power Poster

Registered: 11/02/00
Posts: 2658
Loc: PA
#1 - we use ML Shield by Focus Technology and one of the risk factors it applies to our customers is a geography risk. The system takes the ZIP codes and determines whether the address is in a HIFCA or HIDTA.
_________________________
Opinions expressed are mine and not necessarily those of my employer.

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#1607741 - 09/23/11 10:38 AM Re: Risk Rating Question-Identifying HIFCA & HIDTA [Re: Deena]
dickr Offline
Gold Star

Registered: 02/28/10
Posts: 356
Loc: Middlesex Cty NJ
The last version of BAM that I used (2008) used Zip Codes as one of the factors, but you had to manually enter your Risk Rating for each Zip Code. You had to go to the HIFCA and HIDTA maps to determine which Zip Codes required a higher factor. If they've automated that process since then, it would cut down on the 'prep' work in using BAM.
_________________________
Lord,give me patience - and I want it NOW!!!

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#1607748 - 09/23/11 10:43 AM Re: Risk Rating Question-Identifying HIFCA & HIDTA [Re: Deena]
Ken_Pegasus Offline
10K Club

Registered: 08/30/01
Posts: 17576
Loc: Another trip around the sun
Deena,

If you were trying to evaluate a customer's geographic connections; e.g. they routinely sent wire transfers to another business located in Memphis, would your software help you do that?

Dickr, My understanding is that yours would not.
_________________________
"Oh God, thy sea is so great and my boat is so small." Breton fisherman's prayer in JFK's office.

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#1607774 - 09/23/11 10:56 AM Re: Risk Rating Question-Identifying HIFCA & HIDTA [Re: Ken_Pegasus]
BrianC Online
Power Poster

Registered: 11/26/04
Posts: 2941
Loc: Illinois
#1. Patriot Officer requires the end user to type the zip codes into a rules template themselves. The institution can then assign "points" to those customers living in the regions as part of a risk rating matrix. The more points a customer accumluates based on the templates the user has inout, the higher the risk the customer poses. We have to do the same for all the country codes.

#2. We do take this into account as one of the factors when considering an initial risk rating on new customers.
_________________________
I can do all things through Him who gives me strength. (Phillipians 4:13)

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#1607797 - 09/23/11 11:06 AM Re: Risk Rating Question-Identifying HIFCA & HIDTA [Re: Ken_Pegasus]
Deena Offline
Power Poster

Registered: 11/02/00
Posts: 2658
Loc: PA
Originally Posted By: Ken_Pegasus
Deena,

If you were trying to evaluate a customer's geographic connections; e.g. they routinely sent wire transfers to another business located in Memphis, would your software help you do that?

We could drill down into a particular customer and look at the account activity, including wire transfers. Then, we could drill down into each wire and see all the details of the wire. I'm not sure whether that answers your question. If not, let me know and I'll try again.
_________________________
Opinions expressed are mine and not necessarily those of my employer.

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#1607908 - 09/23/11 12:10 PM Re: Risk Rating Question [Re: Doug Hendrickson]
C Banker Offline
New Poster

Registered: 03/10/06
Posts: 22
The maps are out there...just really hard to locate. Try this link: http://www.whitehouse.gov/ondcp/state-map

You will have to click on each state. It should bring up a "drug control update" for the particular state. The map is the last page of the update.

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#1607968 - 09/23/11 01:04 PM Re: Risk Rating Question [Re: C Banker]
dickr Offline
Gold Star

Registered: 02/28/10
Posts: 356
Loc: Middlesex Cty NJ
Ken - you're correct as to that version of BAM; wire activity (amount, frequency, etc.) could be used as a determinant in the risk-based 'scoring' but the specific wire info, including ZIP/location, had no weight in the equation.
_________________________
Lord,give me patience - and I want it NOW!!!

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#1613455 - 10/06/11 03:10 PM Re: Risk Rating Question [Re: C Banker]
Ken_Pegasus Offline
10K Club

Registered: 08/30/01
Posts: 17576
Loc: Another trip around the sun
Corbin,
Thank you, but the previous maps were based on the HIDTA, not the state. For example, the map of the Appalachian HIDTA included three states as well as the names of the counties in each of them. It was much easier for banks to use based on the footprint of their bricks and mortar.
_________________________
"Oh God, thy sea is so great and my boat is so small." Breton fisherman's prayer in JFK's office.

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