Skip to content
BOL Conferences Top Gun 23
Thread Options
#1904297 - 03/11/14 07:06 PM ACH Report for BSA Purposes
Calmeida12 Offline
100 Club
Joined: Sep 2012
Posts: 249
Does anyone in BSA review any type of ACH report? We have Examiners in house and they are asking us if we have a report that we review for ACH purposes, the same way we have reports for wire activity, loans secured by cash, etc. If you do, can you share with me the parameters of what you look for. Thank you.

Return to Top
BSA/AML/CIP/OFAC Forum
#1904301 - 03/11/14 07:24 PM Re: ACH Report for BSA Purposes Calmeida12
ACBbank Offline
Power Poster
ACBbank
Joined: Jul 2006
Posts: 4,236
New York City
Just my opinion, but ACH reports by themselves don't serve much purposes for AML. ACH activity would typically be used in the layering phase and without knowing the origin/destination of the funds, I'm not sure of the purpose? We will always review ACH activity during KYC reviews or during a review of an account flagged by our transactional monitoring system.

If you have a lot of IAT activity, it might be worth reviewing based on what jurisdictions you consider to be high risk (similar to wires).
_________________________
"100 victories in 100 battles isnt the most skillful. Subduing the other's military w/o battle is the most skillful." Sun-Tzu

Return to Top
#1904315 - 03/11/14 07:44 PM Re: ACH Report for BSA Purposes Calmeida12
Doug Hendrickson Offline
Power Poster
Doug Hendrickson
Joined: Oct 2009
Posts: 3,927
Agree with ACBbank. The ACH activity report by itself doesn't tell you a whole lot. We feed it into our BSA/AML software and produce a series of reports at the end of each month. Some of those reports will indicate international ACH activity, ACH activity followed by cash withdrawals, ACHs to tax havens, ACH activity over certain numbers, amounts and percentages (e.g., ACH spike) that might lead us to perform further investigation. We also can isolate the IATs (which to date have been few, all Paypal, all for small amounts for merchandise coming out of Asia.
_________________________
I hear and I forget. I see and I remember. I do and I understand.--Confucius

Return to Top
#1904363 - 03/11/14 09:01 PM Re: ACH Report for BSA Purposes Calmeida12
devsfan Offline
Diamond Poster
Joined: Jun 2004
Posts: 1,927
NYC
Also, if your customer originates ACH you should be interested in returns and return rates as they could be an indicator of fraud. High vlumes of ACH with other entity names could also indicate a TPPP.

Return to Top
#1905750 - 03/15/14 04:38 PM Re: ACH Report for BSA Purposes Calmeida12
yy2say Offline
Gold Star
yy2say
Joined: Apr 2002
Posts: 279
PA
You can also do key word searches of ACH activity to monitor or identify if your customers are involved with illegal internet gambling or if they now have a privately owned ATM on premises, conduct MSB activity, etc...
_________________________
"Go, Dog. Go!" ~ P.D. Eastman

Return to Top
#1907306 - 03/20/14 08:18 PM Re: ACH Report for BSA Purposes Calmeida12
gcuba Offline
New Poster
Joined: Oct 2013
Posts: 1
Hello,quick question in regards to ACH's. Becomming an Accredited ACH Professional (APP), does it help for a BSA analyst to increase his/her salary? I know about the CAMS will defenitely do, but I'm curious anyway if it will. Also, I'm interested in learning more about the ACH industry as well.

Return to Top
#1907322 - 03/20/14 08:57 PM Re: ACH Report for BSA Purposes Calmeida12
Doug Hendrickson Offline
Power Poster
Doug Hendrickson
Joined: Oct 2009
Posts: 3,927
I would speculate that on your current job, this would depend on your supervisor/manager and your bank's compensation structure. This would be true of any form of certification. Some firms stress the importance of continuing education and do reward those who pursue additional certifications. Some may either not care or need to be educated as to how it increases your value to them in doing your job (always relate it back to the job).

Certainly it's a good line item for your resume that can use in job hunting and may increase your potential for more money.
_________________________
I hear and I forget. I see and I remember. I do and I understand.--Confucius

Return to Top
#2030610 - 07/29/15 08:26 PM Re: ACH Report for BSA Purposes Calmeida12
New Manager Offline
100 Club
Joined: Jan 2004
Posts: 136
Does anyone know of any ACH key word searches I can perform to identify possible TPPPs?

Return to Top
#2038254 - 09/14/15 01:37 PM Re: ACH Report for BSA Purposes Calmeida12
New Manager Offline
100 Club
Joined: Jan 2004
Posts: 136
I'd also be interested in any keywords I could use to search for internet gambling (a recent auditor recommendation).

Return to Top
#2038302 - 09/14/15 03:53 PM Re: ACH Report for BSA Purposes Calmeida12
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 80,325
Galveston, TX
If the auditor made such a recommendation without supplying you with the recommended search criteria, then I would tell them thanks and move on. It is a vacuous recommendation.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#2038348 - 09/14/15 05:32 PM Re: ACH Report for BSA Purposes Calmeida12
ms.understood Offline
Member
Joined: Jan 2012
Posts: 95
Washington
We just had a state examiner recommend reports for various volume considerations...ACH was one of them, new accounts was another.

Return to Top
#2038353 - 09/14/15 05:41 PM Re: ACH Report for BSA Purposes Calmeida12
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 80,325
Galveston, TX
volume consideration??

You mean to help you establish your organization level or customer level risk?
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#2038370 - 09/14/15 06:15 PM Re: ACH Report for BSA Purposes Calmeida12
ms.understood Offline
Member
Joined: Jan 2012
Posts: 95
Washington
Looking at our Risk Assessment, incorporating volumes of each type of listed transaction (ACH, Wires, etc) or new accounts by volume to help understand risk from that standpoint.

Return to Top
#2038383 - 09/14/15 06:45 PM Re: ACH Report for BSA Purposes Calmeida12
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 80,325
Galveston, TX
Well that makes sense, but that is far removed from the key word searches that were being discussed.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#2038689 - 09/16/15 10:24 AM Re: ACH Report for BSA Purposes New Manager
Elwood P. Dowd Offline
10K Club
Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
Quote:
I'd also be interested in any keywords I could use to search for internet gambling (a recent auditor recommendation).


After looking up "vacuous," I agree with rlcarey's response. For decades I've bristled at examiner recommendations that purely indicated they could not find anything of substance. Now, auditors are apparently facing the same dilemma and responding in the same way. My two most recent favorites:

* The bank needs documentation for the percentage of revenues an exempt customer derives from ineligible activities. (There really is no "pat" way to do that and it would require deposit customers to provide information regarding income that some borrowers balk at providing. I'd rescind the exemption instead.)
* The bank should begin identifying beneficial owners of all entity customers. (The requirements should be added to it's CIP.) If the ABA spends 27 pages analyzing FinCEN's proposal as [censored] I don't see the wisdom of adopting it voluntarily. In addition, it falls under CDD, not CIP.

If a bank finds its auditor's recommendation vacuous it should first respond in writing to that effect and second, start looking for a new auditor.
_________________________
In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.

Return to Top

Moderator:  Andy_Z