Just wondering how many "high risk" accounts other banks our size have. Please respond if you are in the size range of $250 million to $750 million. How often do you monitor the activity in these "high risk" accounts? Also, do you have software to monitor the accounts? What general area are you located? Our reason for asking is we know from recent experience that the examiners are saying "based on your size you should be filing more SARs". So, we now expect they will say, "based on your size you should have X number of high risk accounts based on peer comparisions".

We monitor "high risk" accounts on quarterly basis and prepare review and analysis report annually.

We are a 250 Million commercial bank in NYC and have a large number of high risk accounts based upon their business, cash intensity, etc. We track all cash activity on a weekly and monthly basis and investigate each high risk account at least annually, or more often if the pattern of activity changes or something seems suspicious. Similar reports of wire transfer and official check activity are reviewed. We also have AML software that has a set of "rules" than, when broken, are reported. The software has been utilized for only about 1 month so we are still becoming familiar with it. I hope this is helpful.

We are a $600 million community bank with 15 branches located in the Northwest. We currently monitor about 100 accounts we consider high-risk for money laundering. All monitoring is done manually. Based on risk, accounts are either monitored monthly, quarterly, semi-annually or annually.

We perfom a customer-based risk assessment on a quarterly basis to identify any new possible high risk accounts. We are looking at software for future monitoring of accounts--the manual process will not work for long.

You're right about regulators questioning the number or SARs filed and accounts identified. Despite major enhancements to our BSA/AML monitoring systems during the past year, we have not seen an increase in SAR filings. To counter this with our regulators we did an in-depth BSA Program risk assessment to show that our size, location, customer base and product offerings make us low to moderate risk for money-laundering--meaning that there wasn't that much activity to catch in the first place. We do the same type of assessment for our customer base and query peers as to their their SAR activity and level of account monitoring.

We are in the middle of a BSA exam and our regulators have felt our self-assessments have been reasonable.

Good luck.

Thanks to each of you for your helpful responses!!