We do not have an automated solution for this yet. As such, on a quarterly basis our BSA group does a scrub of the MIL to identify any individual that may have purchased more than one MI in the preceeding quarter. If they find any then they send to the AML group who will conduct an investigation.
This is a decent enough process to cover the gap until we can implement automated monitoring. However, it imposes some interesting production constraints.
Firstly, because these are cash purcahses there are invariably never any "alerted" accounts to investigate. As such, we end up doing an investigation of every account tied to the customer, which ultimately end up 99% of the time as a No SAR.
Does anyone have any suggestions on how to modify the language of our procedure (generalized above) or any processes that we could implement to still have a good review process but not bog down production with what has proven to be a useless process?
I was thinking of focusing solely on sequentially ordered monetary instrument purchases who aggregate exceeded $5,000.
Posts, thoughts, opinions and scenarios discussed are my own.