Thread Options
#2028880 - 07/22/15 04:46 PM Account review time frame
Patrick Lee Offline
Junior Member
Joined: Jul 2014
Posts: 25
Rosemead, CA
I am fairly new to BSA and would like to know what other is doing or what is the practice on reviewing an account that is concluded with no suspicious activities and no SAR filing.

The previous BSA officer's practice was if the last review of an account is within one year and is being appeared on another exception after that, he does not review the account again unless it has passed the one year mark or approach to the one year mark. These accounts are the ones that have no suspicious activities and no SAR filing.

The account that has been identified with SAR filing is being reviewed every 90 days.

I understand this is a risk base approach, but nevertheless I am not sure whether this is a good practice. If anyone can share what is their current practice. It will be great.

Return to Top
BSA/AML/CIP/OFAC Forum
#2028892 - 07/22/15 05:07 PM Re: Account review time frame Patrick Lee
PrimeTime Offline
100 Club
PrimeTime
Joined: Nov 2014
Posts: 173
If I'm understanding correctly, the previous BSA Officer saw a customer on an exception (I'm interpreting this as an alert or indicator of potential suspicious activity), and does not review it if he/she has already reviewed it within the past year?

I would absolutely advise against that, as a customer's behavior and activity can certainly change, and although the exception isn't always going to be a true positive, it should absolutely still be reviewed in a reasonably timely manner. Depending on what other things there are to review at your institution however, the approach may be taken that the other monitoring devices employed are able to more adequately detect potential suspicious activity.

Our practice is if it appears on an alert, exception, case, report, whatever monitoring device we have, we review it to ensure that we either have a false positive, or report the suspicious activity.
_________________________
Life is like a bicycle. To keep your balance, you must keep moving.
-Albert Einstein

CAMS

Return to Top
#2028895 - 07/22/15 05:14 PM Re: Account review time frame Patrick Lee
JacF Offline

Power Poster
Joined: Nov 2001
Posts: 6,719
PA
If I'm understanding your previous BSA Officer's process correctly, it sounds like he was giving certain customers a one year "pass" on suspicious activity reviews? Regardless of the criteria used for making such a determination, I would expect the practice of exempting a customer from monitoring/review to be criticized.

To underscore what I mean, here's a real-world example:
We have a customer whose shenanigans prompt us to occasionally file. The customer's business experiences seasonal swings, so the shenanigans typically happen in the same season each year. A typical season prompts an initial report (say, in January) and a 90 day continuing report (around April). If I follow the model that your previous BSA officer used, when I do my 90 day review in July, I may conclude that the activity has ceased, and set the account to review the following April. In doing so, I am settign myself up to miss (and fail to report) the shenanigans that the customer engages in next January.

I suggest the following:
-Any customer with a 90 day review in the queue gets reviewed according to that schedule.
-All other customers are subject to regular monitoring and event-based review, whether they have had SARs filed in the past or never at all.

Return to Top
#2029079 - 07/23/15 12:51 AM Re: Account review time frame PrimeTime
Patrick Lee Offline
Junior Member
Joined: Jul 2014
Posts: 25
Rosemead, CA
Thank you for the suggestions! Is your practice to perform a full review when these accounts are showing up on the alerts or exceptions?

Return to Top
#2029160 - 07/23/15 02:20 PM Re: Account review time frame Patrick Lee
PrimeTime Offline
100 Club
PrimeTime
Joined: Nov 2014
Posts: 173
Depends on what your definition of a full review would be. Some alerts or exceptions may warrant more due diligence than others. Regardless, all of the behavior noted in the exception/alert should be reviewed, so in that context it would be a "full review". But if full review were to pertain to the customer's entire relationship with the institution, it would be on a case-by-case basis.
_________________________
Life is like a bicycle. To keep your balance, you must keep moving.
-Albert Einstein

CAMS

Return to Top
#2029283 - 07/23/15 05:55 PM Re: Account review time frame Patrick Lee
JacF Offline

Power Poster
Joined: Nov 2001
Posts: 6,719
PA
I agree. The size and scope of the review are going to be dependent on the nature of the activity, the complexity of the relationship, and the bank's understanding of the customer's activity from due diligence and historical data.

Return to Top
#2029662 - 07/24/15 06:42 PM Re: Account review time frame Patrick Lee
Patrick Lee Offline
Junior Member
Joined: Jul 2014
Posts: 25
Rosemead, CA
Thank you both for the information! Greatly appreciated!

Return to Top

Moderator:  Andy_Z