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#119449 - 10/02/03 02:11 PM Monitoring Wire Transfers for Suspicious Activity
Anonymous Unregistered	We are attempting to improve our efforts for monitoring wire transfers for suspicious activity, and would like to know what criteria other banks are using. We all know about the classic cases (e.g. cash used for wires), but what about a deposit account holder that sends frequent transfers to beneficiaries that are not on the account that the funds were debited from? Is anyone aware of any software or filters that could be used to assist in the process?
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BSA/AML/CIP/OFAC Forum

#119450 - 10/02/03 09:15 PM Re: Monitoring Wire Transfers for Suspicious Activity
Anonymous Unregistered	Is anyone able to help with this? My bank is in the process of discussing the same issue, and is not sure how best to proceed.
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#119451 - 10/02/03 10:02 PM Re: Monitoring Wire Transfers for Suspicious Activity
Anonymous Unregistered	It sounds like you're talking about book transfers. We use a separate tran code for those transfers. Our software picks them up from the block posts and they're aggregated with other BSA data. We use solutions from Banker's Toolbox for BSA/AML compliance and wire automation.
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#119452 - 10/03/03 12:56 PM Re: Monitoring Wire Transfers for Suspicious Activity
Anonymous Unregistered	Can you provide me with a little more detail about the process you use. Where can I get more information?? (Thanks for your assistance!!)
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#119453 - 10/03/03 01:09 PM Re: Monitoring Wire Transfers for Suspicious Activity
complyguy Gold Star Joined: May 2001 Posts: 494 PA	One thing we've reported is incoming wires followed by outgoing wires for smaller amounts nearly equal in total to the amount to the incoming wire, especially with offshore banks involved.
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#119454 - 10/03/03 01:53 PM Re: Monitoring Wire Transfers for Suspicious Activity
Anonymous Unregistered	We have our AML software set up to track suspicious wires based on rules we have written. Prior to purchase of the software we monitored wires to/from a list of select countries (FATF plus others). It was a combination of an automated and manual process. We would query our wire system based on the country name for a listing of wires. They would then be manually entered into an Excel spreadsheet and sorted by county, by name, by address and by either beneficiary (if outgoing) or originator (if incoming). It was amazing the things we found! Not sure if that helps, but it worked for us until we had the AML software installed. Now you should see the stuff we get! YIKES!
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#119455 - 10/03/03 06:08 PM Re: Monitoring Wire Transfers for Suspicious Activity
Anonymous Unregistered	Thanks for the feedback. Can you provide me with some information about the AML software you purchased, like vendor name and contact info??
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#119456 - 10/03/03 08:54 PM Re: Monitoring Wire Transfers for Suspicious Activity
WildTurkey Platinum Poster Joined: Jan 2003 Posts: 921 Down South, USA	Quote: One thing we've reported is incoming wires followed by outgoing wires for smaller amounts nearly equal in total to the amount to the incoming wire, especially with offshore banks involved. From my training (direct from the Fed, albeit a few years ago) you should also be looking for accounts that accumulate a balance over time from small deposits and/ or inward transfers, with the balance then reduced substantially by an outward transfer; this may then be followed by further repeated accumulations and transfers. _________________________ This is my opinion; it is not legal advice, nor the view of my employer, and it may change tomorrow.
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#119457 - 10/03/03 11:04 PM Re: Monitoring Wire Transfers for Suspicious Activity
complyguy Gold Star Joined: May 2001 Posts: 494 PA	WildTurkey - Yes, we've done this as well, but thanks for the advice.
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#119458 - 10/06/03 07:11 PM Re: Monitoring Wire Transfers for Suspicious Activity
Anonymous Unregistered	In our Bank we use the software of Banker's tool box called BSA Manager which sorts data based on SS/TIN no. You can get more details from their website at www.BankersToolbox.com It is also reasonably priced and the feedbacks we got from other users were positive- S.K
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#119459 - 10/06/03 07:23 PM Re: Monitoring Wire Transfers for Suspicious Activity
rlcarey 10K Club Joined: Jul 2001 Posts: 83,364 Galveston, TX	If I'm a person trying to figure out ways to stay under the screen of bank's wire transfer monitoring procedures - let's see - what would I do - hmmmmmm - I know - I'll ask them directly by pretending that I am a banker...... Giving leads regarding software and service providers is one thing. Talking about specific monitoring techniques may not be in our best interests. _________________________ The opinions expressed here should not be construed to be those of my employer: PPDocs.com
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#119460 - 10/06/03 09:10 PM Re: Monitoring Wire Transfers for Suspicious Activity
Anonymous Unregistered	Relax. I'm a banker, and we REALLY are trying to step up our monitoring efforts in this area. The bad guys can probably glean more techniques from the web than they can from this thread. Thanks for everyone's input.
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#119461 - 10/07/03 02:42 PM Re: Monitoring Wire Transfers for Suspicious Activity
complyguy Gold Star Joined: May 2001 Posts: 494 PA	Quote: If I'm a person trying to figure out ways to stay under the screen of bank's wire transfer monitoring procedures - let's see - what would I do - hmmmmmm - I know - I'll ask them directly by pretending that I am a banker...... Giving leads regarding software and service providers is one thing. Talking about specific monitoring techniques may not be in our best interests. Point well taken. Thanks.
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#119462 - 10/07/03 06:42 PM Re: Monitoring Wire Transfers for Suspicious Activity
WildTurkey Platinum Poster Joined: Jan 2003 Posts: 921 Down South, USA	Quote: ..... Giving leads regarding software and service providers is one thing. Talking about specific monitoring techniques may not be in our best interests. Is it better to keep quite to stop crooks from sharing our information or to share the knowledge to help fellow bankers identify improper account activity? There are arguments for both and is ultimately a judgement call. When Federal government institutions such as (but not confined to) FINCEN publish their bulletins and guidelines on money laundering and other suspicious activity on the web (as well as in hard copy) - try the FATF Report on Money Laundering Typologies for starters - I find it hard to believe that a few posts on a BOL thread are going to have a material impact on the amount of knowledge in the hands of crooks! _________________________ This is my opinion; it is not legal advice, nor the view of my employer, and it may change tomorrow.
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#119463 - 10/08/03 03:37 PM Re: Monitoring Wire Transfers for Suspicious Activity
MagicCity Power Poster Joined: Apr 2003 Posts: 3,003 Fort Lauderdale, Florida	Is there any chance of you sharing those rules? I would very much appreciate it. Thanks.
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