Please refresh my memory as to why our BSA officer would have to review the Garnishments and Levys?

Personally, I am the BSA officer and I wasn't reviewing them. FRB was not too happy, said I need to be reviewing them or at a minimum informed when someone received more than one, customer is often higher risk for kiting, & bank fraud in general. Or at least, that is what I was told by the EIC.

O.k. so when you see one that is being garnished do you review their statements for a certain period of time to determine if the customer has been kiting or had any suspicious activity in the account?

I am the BSA Officer and happen to also be responsible for processing garnishments and levies at the bank. I have a log for those and other officers can see that on our shared drive. May I suggest you get copied or have access to the records/log your legal processor has.

Reviewing the accounts when receiving a garnishment or levy is an automatic for us. You never know what you might find. I also document the review of the account in our BSA records.

Thanks for the info. I knew there was a valid reason for her review of these items however I could not for the life of me remember why. Brain fried!!!

I disagree with the EIC who said that the BSA officer should be reviewing garnishments and levies; based on what? Grand Jury subpoenas and IRS Summonses are certainly a different story but not the run-of-the-mill garnishments and such.

I was too new to even contemplate disagreeing I just said "oh, okay" and have reviewed ever since (it's been about 6 months)... I haven't found anything interesting yet, but I (like Florida babe) review account activity, go back a few months and add them to my higher risk customer list that gets monitored quarterly... I have pushed to close a few of those customers based on the time requirements for monitoring, but that is the only thing that has changed for us...

I agree with devsfan. The BSA Exam Manual talks about the monitoring of "Law Enforcement Inquiries and Requests". A run of the mill garnishment or levy is neither. Law enforcement requests are key, as there may be a violation in law involved. The others - they just owe someone money.