I am in the process of auditing BSA and have a dilema. I need to determine whether we have an effective system to detect multiple sales of monetary instruments in one day, totaling $3,000 or more.

We do have a system in place to detect transactions $3,000 or more. Those transactions are reported on a Suspicious Activity report as well as MIW's are completed.

The question I have is the $3,000 starting point we have - is that suffecient. For example, if a customer/non-customer purchased several $2900 teller checks in one day at different locations there would be no way for our bank to detect that. If they purchased several $3,000 checks in one day we would detect that because an MIW would be completed and it would show up on our SA report.

Your system won't aggregate by input name/account number, to recognize aggregated activity over the threshold? In light of the Western Union settlement, I would think you would want to address this issue. One of my clients uses a $1500 starting point.

No, we aren't online. The report is designed to only pick up transactions greater than $3000. And a teller of course is only required to complete MIW's greater than $3,000.

To be able to pick up less than that amount we would have to collect information on every purchase of a monetary instrument.

That was me...forgot to sign in.

Our system aggregates by tax number and account number and our threshold is $1000. It aggregates all branches.