Customer Service v. Suspicious Activity
Bank employees are supposed to give excellent customer service. That means smiling at all customers, calling them by name, and providing them with information they request and the best service possible. But at the same time, the bank employees are supposed to identify suspicious activity. So how does a person distinguish between giving service and being suspicious?
Law enforcement officials have some guidance about suspicious activity that might help. At the Money Laundering Enforcement Seminar jointly sponsored by the American Bankers Association and the American Bar Association, the nation's "Drug Czar", General Barry McCaffrey, shared some examples of the way money launderers may conduct banking activity. This type of suspicious activity might include:
Multiple bank accounts opened by more than one foreign national on the same day.
Multiple bank accounts opened by the same individual using variations of the individual's hyphenated surname.
An account opened using a foreign address or an address marked "in care of".
An account opened with an invalid Social Security Number.
An account opened without a residential phone number being provided, or in which a cellular phone or pager number is given as the reference telephone number on the account opening forms.
These are the examples of transactions and banking activity that bank employees should spot and question. The examples are based on practices that have been identified in previous law investigations. Some of these techniques can be caught by the front line while others can only be identified through regular monitoring in operations, audit, or compliance.
And while identifying these circumstances - and others - remember to give good service!
Copyright © 1997 Compliance Action. Originally appeared in Compliance Action, Vol. 2, No. 14, 12/97
First published on 12/01/1997