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#1620906 - 10/27/11 03:29 PM BSA/AML Risk - Sending Money Online
NewNana
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The bank is previewing a new bill pay system that allows payment to anyone, anywhere, for any purpose without revealing any identifying information re: the recipient. These payments can be sent via text, email, or to another FI. From a BSA/AML perspective, what would you recommend in terms of controls? Or can you point me to a resource/guidance for enhanced bill pay functionalities such as these? Thanks!

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#1620916 - 10/27/11 03:33 PM Re: BSA/AML Risk - Sending Money Online
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,277
To start, compare it to what a person can do with sending a check, for one thing. What do you know about check recipients?

Then look at OFAC and other location/geographic issues.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#1621040 - 10/27/11 05:41 PM Re: BSA/AML Risk - Sending Money Online
ACBbank Offline
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ACBbank
Joined: Jul 2006
Posts: 4,176
New York City
Originally Posted By: NewNana
The bank is previewing a new bill pay system that allows payment to anyone, anywhere, for any purpose without revealing any identifying information re: the recipient. These payments can be sent via text, email, or to another FI. From a BSA/AML perspective, what would you recommend in terms of controls? Or can you point me to a resource/guidance for enhanced bill pay functionalities such as these? Thanks!


Good luck with that.
_________________________
"100 victories in 100 battles isnt the most skillful. Subduing the other's military w/o battle is the most skillful." Sun-Tzu

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#1621047 - 10/27/11 05:51 PM Re: BSA/AML Risk - Sending Money Online ACBbank
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,277
You might also ask the vendor for references/contact info from banks that are already users of the product. You don't want to be on the bleeding edge of a product (or you might, depending upon your risk appetite.)
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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