Has anyone out there combined their fraud and BSA departments? If so, can you provide some insight on how to begin the process? What "fraud" pieces exactly reside in this area? Any info is appreciated!

I am a Fraud Prevention Manager and the bank's BSA Operations Officer. It was fairly easy for us because we can review the same types of reports and alerts for both fraud and BSA. In my opinion they pretty much go hand in hand. I have had differing opinions from examiners/auditors. Some like to see them combined...others not so much.

they are combined at our bank in the Loss Prevention Dept.

I'm the BSA & Fraud Officer - in the Risk Management Dept.

$1B bank - so hoping to get some help soon - but the functions will stay in Risk Management as a combined effort.

not sure anyone answered the original question- Is there a difference between Fraud and BSA issues- or in all cases do they overlap?

I believe they overlap - but where you may have different procedures is in regards to dollar amount.

A customer who's passing bad checks, but you stop them at $500, wouldn't be a BSA issue perse (SAR requirements give a $5,000 threshold), but you may still contact Law Enforcement to attempt to collect reimbursement.

I have a Fraud Department Program and a separate BSA Program. However many topics in my Fraud procedures do overlap and refer to the BSA Program if thresholds are met.

Check this out. It's free, and free is good. It's about FRAML (COMBINING FRAUD and AML)and it is from ACAMS.

https://netforum.avectra.com/eWeb/Dynami...6e-7c9edbdc32c5

The webinar starts at 12:00 AM? I'll be sleeping then.

Good catch! I do my best thinking and learning when I am asleep, don't you? I think they mean 12 Noon, otherwise it is going to be a very long Webinar.

It says 12PM on the top of the page...

Yeah, I sent them an email telling them they needed to change the time.

Careful with that webinar, I've found it's more of an advertisement for the Verafin product than an actual presentation about combining your Fraud and AML Departments.

For what it's worth, I've worked in multiple institutions that combined Fraud and AML to different degrees. One of them was a larger bank, which had separate departments but shared the same case management system - which provided a good channel for exchanging information. Logistically, it didn't make sense for them to completely combine. Having worked at both sides of the fence in that bank, I'd say there was a mindset difference between the two groups. Fraud/loss prevention seemed to be fast-paced, black-and-white, and quantifiable. AML was more methodical, qualitative, and focused on subjecive, "gray" areas. From a detection system perspective, the only time they seemed to cross paths was with kiting, which would get flagged for layering rules and check fraud rules in separate programs. Therefore, they were better off separated since they could hire personnel focused on their respective areas.

At my current institution, there's a higher degree of workload sharing; both as a matter of resources and taking advantage of the similarities each function has. We're a smaller bank, so justifying expenses can be difficult and everyone's used to wearing multiple hats. In my opinion, the whole "FRAML" thing works better at smaller institutions.

To get started, take stock of the functions and resources within each department and see if and where it would make sense to combine. If you don't have AML or fraud software, Verafin might actually be an attractive option (not an advertisement) because of the resource savings and efficiencies it provides by including both functions in one system.

We have a semi-combined Fraud/BSA Department. Our BSA Officer is our Fraud Officer and oversees functions across the line, but we have separate BSA & Fraud Analysts.

Our division is straight down the line of currency...if it's cash related then BSA handles it, if it's paper item (kiting, counterfeiting, forgeries, large item verification, etc) related then Fraud handles it. (ACH Fraud is handled through our electronic banking department). Because all of the analysts report to one person, our officer is able to get the 'big picture' and cross reference, but analysis on the peon level (me) happens separately using two different programs.

Analysts for both functions 'live' in the same office space, so conversations about suspect activity that may be of interest to the 'sister' department is freely shared...but analysis duties are completely divided.

We're considering doing this now in our bank; the BSA Officer would take on the fraud/loss prevention and security officer role. We're creating the new position to separate out the compliance officer's multi-function role as compliance/BSA/CRA officer.

Does anyone have a job description for this (or just for security/fraud officer?