I am the BSA Officer for our intitution. We have recently purchased the Yellow Hammer BSA & Fraud Detect. A portion of the Fraud detect helps me as the BSA Officer investigate check/cash kiting. The Lending Compliance Officer uses Fraud Detect for the Identity Theft portion. However there is a portion that is not being utilized. We are a small bank, around 150K. Any suggestions on who in the insitution should be in charge of the fraud portion? Fraud is totally different than BSA so I have never actually been looking for this in particular. Our security officer title is on a person who wears many hats.

Our fraud detection software is housed in our BSA department. It seems to be a good match for the skill set.

I handle both the fraud investigations in addition to BSA. It works well.

YellowHammer Fraud Detective is housed in our Fraud Department. I started our Fraud Dept and am now the Security Officer with Fraud still in my area. We actually have other departents who utilize different functions (ACH is done in Bookkeeping, for example), but we have 2 full time employees who use YH working On-us and Deposit items. Our Cards area uses a different system altogether for card fraud.

It's a bit disjunct, but it seems to work well for us.

Since someone is already pulling up YH-BSA, why not give them some additional training on what to look for in the fraud module/area. It will cut down on the time being on the system and additionally help cross train people (or at least make them conscious of what is happening). If there is a "hit" or indication of fraud, have them refer it to fraud.

Caveat, make sure the fraud person is involved with setting up the parameters for the fraud program. JH will help out with that.

I am the BSA/AML Officer for our institution as well. We recently implemented AML Manager from Fiserv and and are getting familiar with using software.I was informed the Bank would like to expand my Dept. to include Fraud also. I am looking for any guidance you may have to offer. This would be all new to me and I'm not even sure where to start.What are the regulatory requirements, what resources are necessary, what classes or training are needed? We are approx.500k stong with a BSA/AML Officer and part time assisant.

Our Fraud department covers things such as Counterfiet checks, forgeries, unauthorized paper drafts, kiting. They use Yellow Hammer by Jack Henry to monitor the kiting and on us items to check for check numbers out of range. They send e-mails notifying the branches of current fraud schemes going around and host training a couple times a year.

When I began our Fraud Dept in 2003, I began simply by looking for kiting. When the scam check issues took off, that was my focus. We handle the same things as does James T.

Many banks, however, have a centralized fraud department which handles debit card fraud, ach and wire fraud, as well as check fraud. While we cross over now and then, our fraud department is check-oriented. Our cards department handles all card fraud matters, and our bookkeeping department handles all ach matters.

Our fraud department consists of 2 full time employees dedicated to check fraud with one full time employee whose focus is on security but assists with fraud. We are also looking to add one more parttime employee for check fraud.

We are a Jack Henry bank, similar to James T above. We are under $500Million with 36 banking locations and one Operations-only location. Hope this helps.

We are also a JHA bank and we have the fraud department and the BSA department together. We have an employee dedicated to reviewing Fraud Detective and another that does YHBSA monthly.

It seems to work well for us. We also handle check fraud and other types like Pup and James T.

This small bank has the retail branch officers review and dispose their own accounts flagged in YH Fraud Detective on a daily basis. I think the retail branch officers are predisposed to their own customers and they are not independent during the review process. At their own discretions, the retail branch officers report suspicious/fraud activity upon routine review to BSA/AML for filing or nonfiling SAR.

Does any bank allow the Retail Branch Staff directly work the YH Fraud Detective? Where the YH Fraud Detective belongs? What do you see the potential problems in this arrangement?

Any input is much appreciated.

You have already hit on the most important issue, you have the fox watching the chicken coop. Reviews should be independant from the retail branch's control, as they think all of their customers are "good customers" and they think they know what they are doing. The independant review at least allows for the hard questions to be asked.