In your due diligence for BSA, how are you monitoring wire transfers? We are trying to figure out how best to incorporate monitoring of wires into our current program - What to examine? What to look for? Only look at wires paid in cash?

I would look for wires that seem unusual or do not appear to be consistent with the nature of the business. Also look for frequent incoming and outgoing wires for round dollar amounts and wires sent offshore, say to the Cayment Islands.

We have had pyramid schemes, investment schemes and loan fraud committed at our bank. All were detected when an alert employee noticed unusual wire transfer patterns.

Also look for outgoing wires shortly after deposits of large sums of cash or monetary instruments.

We only send and receive wires for customers. Our customers have already been screened.

But, I also download on a monthly basis all transactions from the account statements with tran codes for wire credits and debits into an excell spreadsheet. The spreadsheet contains a rolling 9 month wire transaction activity. This spread sheet is sorted by account number and by date. This shows by account all incoming and outgoing wires and the date and amount. A review of this spreadsheet will show suspicious activity. One drawback is it does not show originator or benefinicary depending of type of wire.

I also download daily cash trans into a separate spreadsheet that has a 9 month history by account number.

The examiners have stated that it is the best monitoring that they have seen.