Does your FI prohibit the processing of international pouch activity and offer lockbox? If so, how do you monitor pouch activity for your Non-US lockbox customers?

If so, how do you monitor pouch activity for your Non-US lockbox customers?

Very, very carefully. You are talking about a service that I think few of the community banks that participate here would even touch. The best thing to do is review all the documentation in the BSA/AML examination manual to make sure you have properly identified all the risks and develop the proper controls and monitoring processes. Maybe someone that actually engages in this type of activity will chime in. None of the banks that I work with would even think about getting involved in this activity. It is usually reserved for banks that have dedicated international banking divisions. If you are a small bank, you have to ask yourself, why is this customer at my bank? I see small banks get suckered into these arrangement because the bigger banks will not touch them. Since the big crackdowns on this type of activity by the regulators, money launderers are looking to pray on smaller institutions that may not know better. Tread carefully.