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#1905684 - 03/14/14 08:24 PM Staff Suspicious Activity Incentive Program Ideas
WY Banking Offline
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Does anybody have a Suspicious Activity Incentive Program in place? Would you be willing to share information about what is working and what is not? We have suspicious activity forms available plus regular training on red flags with examples but nothing much materializes beyond what our BSA staff finds.

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#1905688 - 03/14/14 08:38 PM Re: Staff Suspicious Activity Incentive Program Ideas WY Banking
rlcarey Offline
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Galveston, TX
I would be afraid it is going to turn some of the employees into Sherlock Holmes smile Not sure you want them spending that much time on trying to investigate customer in order to win a prize. I would be looking at what the BSA department is finding and determining if it should have been noticed by other staff prior and use those as training examples.
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#1905691 - 03/14/14 08:40 PM Re: Staff Suspicious Activity Incentive Program Ideas WY Banking
MrsSmithCRCM Offline
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I would think a management emphasis is more of what you are looking for. Along with a, when BSA dept finds something confronting any applicable tellers- ie structuring, kiting, etc, why didn't you notice this? type of approach.

We don't have any sort of incentive program, basically we have mgmt that carries the, pay attention this is important or you don't have a job much longer attitude.

Is mgmt not on board? We discuss BSA at least quarterly here, as well as circulate inner office emails about latest and greatest issues we are seeing, keeping everyone informed and BSA in the forefront of their minds... hopefully.

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#1905692 - 03/14/14 08:41 PM Re: Staff Suspicious Activity Incentive Program Ideas WY Banking
MrsSmithCRCM Offline
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I agree with Randy as well, you don't want your employees in a witch hunt, they need to do their job and know that is part of it.

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#1905697 - 03/14/14 08:47 PM Re: Staff Suspicious Activity Incentive Program Ideas WY Banking
Elwood P. Dowd Offline
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This is one of those areas where the stick is more appropriate than the carrot; the incentive is the fact that when you do your job you keep your job.
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#1905707 - 03/14/14 09:12 PM Re: Staff Suspicious Activity Incentive Program Ideas WY Banking
WY Banking Offline
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Joined: Nov 2013
Posts: 37
The replies make sense so far. I wouldn't want anyone to "Sherlock" and not maintain productivity. I am interested in creating a regional BSA/AML related newsletter to share at least quarterly for the whole staff and maybe a monthly email touching on the latest issues for management.

After an independent BSA/AML audit we are adding enhanced due diligence to our policy so I know we will need to include everyone to be successful. (We were properly monitoring our few high risk customers but never formally added the procedures etc to our policy.)

Also bank wide training emphasis the past two years has been on customer service but from my standpoint "light and fluffy" customer service only. I believe we need to enhance are Customer Service training to embrace the recent Enhances Due Diligence policy addition to better understand the customer's profile/identity in general. But to also be prepared as we encounter more high risk or suspicious activity circumstances.

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#1905710 - 03/14/14 09:20 PM Re: Staff Suspicious Activity Incentive Program Ideas WY Banking
edAudit Offline
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edAudit
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The point of your request is to get Suspicious Activity adding the incentive you will get activity not necessary suspicious. If there is nothing when reported and something later the questions will be why did you miss it? (even though there was no suspicious activity when reviewed).
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#1905751 - 03/15/14 04:48 PM Re: Staff Suspicious Activity Incentive Program Ideas WY Banking
yy2say Offline
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yy2say
Joined: Apr 2002
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PA
IMHO you might be treading on thin ice with the confidentiality component of SAR reporting. If folks are working hard to win incentives, they will be talking and I'm not sure that is a good thing.
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