I am starting a process of creating a program to review our exempt customers for suspicious activity. We look at a few reports, but we are looking for a "set" program to follow. Does anyone know of a program, or example format?

I don't think that you are going to find anyone who is going to give you what you are looking for especially not on a public chat area. You might want to talk with other professionals in your area, or your examiners to see what they are doing or what they are looking for.

Good Luck!

I will tell what we basically do. We do not exclude any Phase II exempt customers from our day-to-day suspicious activity monitoring. We DO exclude Phase I exemptions from this monitoring. Also, we do Enhanced Due Diligence on the Phase II exemptions so that we show we truly know our customers.

We do the same as Wanda and it seems to work really well. We have the account managers fill out a due diligence worksheet which is a series of questions about their customer. The auditors seemed to really like this sheet.

Jace,

You can pull 3 to 4 months statements and review the deposit/withdrawal activity on the account to ensure it is consistent with what you would expect for the business type. I would assume your bank did a site visit before exempting the customer. You might consider requiring a visit each year when you do your review, just to make sure everything seems right.

Doing this review also gives you an opportuity to determine if the customer still qualifies for exemption. By that I mean that they are still conducting regular cash transactions over $10,000.

Thanks for all the help.

Do you have a large cash transaction report? I review that monthly to see cash transactions at or just below the $10,000 threshold. It also takes into account loan payments. I found a customer who paid off a loan via $10,000 transactions on three consecutive days. The loan officer didn't think this was suspicious because the customer told her that he was selling his business and as he sold off his equipment he made payments to pay the loan down and eventually off. The old fashioned "eyeball" method found that structuring.

We do have a large cash report. And we do review it. But we are looking for a "form, format" to use in reviewing our exempt customers for suspicious activity. Maybe we just need to condense the things we already do. Are there any other suggestions, or example formats, forms?

What we've heard from the Examiners is to do a review of all cash transactions done by the customer, to see if anything sticks-out like a sore thumb. For example, you may find that most of a customer's cash deposits are between $10,000-$20,000. If they had one or two during the year that were way outside of the norm (for example, a $60,000 cash deposit), you'd likely want to file a SAR.