The BSA exam manual lists attorneys, CPA's, etc as potentially high risk. This may seem like a broad question but what do you all do to monitor the activities of attorneys, most don't have high cash volume, mainly wires and conveyancing checks. Monitoring trends for high cash businesses seems like a no brainer but what about attorneys? Thoughts?

We identify IOLTA accounts and review their activity annually. Everything else falls into our normal monitoring based upon thresholds for cash, wires, other high-dollar activity, and possible structuring.

The risk for attorneys & CPAs comes not from their garden variety operating accounts for their practices, but from accounts in which client funds are comingled, which could facilitate laundering. Those are the types of accounts, in general, you want to look for and consider higher risk. AR.

So IOLTA accounts but it's mostly wire transfers and conveyancing checks for loan closings. So I'm still not sure what things I should be reviewing or documenting for due diligence purposes.

If the wire transfer and check activity appears to be for loan closings, claims settlements, etc you can document that the activity is consistent with expected but if you are seeing wires to other countries (tax havens, etc), or cash activity then you have further due diligence that should be done.

The reverse is true as well. Incoming wires from an offshore shell company with funds then remitted to a person/entity associated with that shell comany...but here in the US.

Or an attorney acting as 'escrow agent' for a VOD or tax credit scam.

Seen them both....recently

We have had a lot of attorneys charged in mortgage fraud, investment fraud, money laundering cases, etc. As far as I am concerned, all attorneys are high risk.