We have a Trust Department (Asset Management) which is seperate from the Bank. During our recent OCC exam, they inquired what I am reviewing and/or monitoring on the Trust accounts.

Right now, our Trust system is seperate from our core operating system and I do not do any monitoring of transactions. They also never handle currency. While we were not cited during our exam for having inadequate monitoring, they did mention we should be reviewing Trust transactions. Does anyone else monitor this activity? If so, what types of reports are you looking at and what is the frequency?

I haven't had any luck finding guidance on this, other than CIP- which we are okay with. Any input is appreciated.

Jenny ftb: There is a section in the BSA Exam Manual on Trust and Asset Management services that contains information on risk mitigation:

http://www.ffiec.gov/bsa_aml_infobase/pages_manual/OLM_083.htm

Yea, we have all of that in place...and are familiar with that guidance. However, the OCC indicated that I should be reviewing accounts for suspicious activity and in comparison to our "bank" customers. For example, if they are high risk on the bank side, what about the Trust side, etc. Just wasn't sure if there were specific types of reports that I should be reviewing on a regular basis.

I didn't discuss in depth with the OCC for fear it would turn into something more than just a verbal comment.

We also have a Trust Dept. and I created a BSA/AML risk form for all new accounts. The form gives several pieces of information such as the customer's name, source of funds, who has authority to move funds, any High Risk countries involved etc. Then I keep track of all the opening details on a spreadsheet. Then I risk rate the ones with the customer in control of moving the funds as a higher risk. However, as to regular monitoring, I don't do that. Trust personnel are trained in SAR activities and have to report to me anything suspicious they see when they do their yearly reviews. I have 3 BSA questions on their yearly review sheet that would direct them to contact me if any suspicious activity is seen. The OCC checks Trust's yearly review processes and that keeps Trust accountable to communicate with me if necessary. If money moves between the bank side and trust side, we investigate both if needed. We have the OCC as our regulator and that has been fine with them.