Does anyone include a review of internet banking bill pay activity with their BSA monitoring. Our auditor made the recommendation that we review activity for unusually high checks written for internet banking accounts. Just curious if this is a common practice.

We do not. Our bill-pay program is relatively new and I guess I never thought about it.

We are looking at AML software vendors and YES - the two we are seriously considering both include all electronic payments as part of the customers overall account activity to be monitored. The monitored electronic payments include wires, ACH, debit card and internet bill payments. (I was assuming you were thinking AML when you said BSA - for internet bill paymers are not cash transactions and you'd never need to complete a CTR on them.)

Yes, I check the list of bill payer payments every day for any unusual transactions.

so you screen every ACH transaction (onus and transit items?) does your core processor to the screening or do you have a solution?

If a match is identified, how do you follow-up? It seems like you could only do a Name match against the OFAC list. Do you contact the "originator" or the receipients DFI?