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#1077264 - 11/05/08 09:29 PM MONITORING ATM TRANSACTIONS
LisaL Offline
Junior Member
Joined: Oct 2008
Posts: 35
Does anyone want to share how they incorporated their ATM cash activity monitoring in their BSA/AML policy? I have an excel sheet for my head teller to list cash activity through the ATM machines. Did you keep it the same dollar limits i.e. monetary instruments $3k to $10k? what if a customer deposited on a daily basis $1K? Is it smart to record EVERY cash transaction through the atm?
Anyone have any helpful hints for me?
tia!!!

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#1077361 - 11/05/08 10:30 PM Re: MONITORING ATM TRANSACTIONS LisaL
Maytagman Offline
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Maytagman
Joined: Jun 2008
Posts: 285
South
If you accept cash deposits at ATMs, will you be including all of that in your CTR reports too?

For suspicious activity monitoring purposes, I review all customer ATM transactions periodically, and look for unusual patterns (dumping it into a spreadsheet then sorting by name). Most customers have only handful of transactions; some may have 10 or 15 in a month. I usually stop and take a looksie if it is over about 12 in a month, but have never had that generate a SAR. In theory I'm looking for a person who has three times as many ATM withdrawals as any other customer (60 ATM withdrawals in a month, with the maximum allowable amount on most of them). We don't accept cash deposits at the ATM so that simplifies mine a bit.
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#1077616 - 11/06/08 02:31 PM Re: MONITORING ATM TRANSACTIONS Maytagman
LisaL Offline
Junior Member
Joined: Oct 2008
Posts: 35
Hmmm no cash deposits accepted at atms, that sounds nice but would never fly around here :-(
My thoughts were to have the cash deposits listed on an excel spreadsheet for monitoring, that way I can sort by name and if needed file a CTR that way?
Thoughts?
TIA

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#1077716 - 11/06/08 03:44 PM Re: MONITORING ATM TRANSACTIONS LisaL
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,858
Cape Cod
At my last bank, our branches reported any cash deposit over $1,000 to our ATM department, which added them to a spreadsheet. We reviewed that spreadsheet in conjunction with our large cash deposits report to see if any ATM deposits tipped the $10,000 mark for a CTR. We also used it each month to review non-business accounts reflecting high deposit activity to see if suspicious patterns developed.
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#1078473 - 11/07/08 01:07 PM Re: MONITORING ATM TRANSACTIONS John Burnett
LisaL Offline
Junior Member
Joined: Oct 2008
Posts: 35
Thanks !!

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#1079034 - 11/07/08 06:51 PM Re: MONITORING ATM TRANSACTIONS LisaL
P*Q Offline

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P*Q
Joined: May 2001
Posts: 8,458
Somewhere
On a daily basis, each branch sends up a report of any cash deposit exceeding $500.

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#1080321 - 11/12/08 01:15 PM Re: MONITORING ATM TRANSACTIONS P*Q
LisaL Offline
Junior Member
Joined: Oct 2008
Posts: 35
Thanks everyone, much appreciated!
How did you incorporate this into your BSA/AML policy?

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