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#2083591 - 06/15/16 06:14 PM Monitor check activity
Cher Offline
Joined: Oct 2003
Posts: 98
Florida, USA
Our examiner has recommended that we expand our monitoring processes to include checks. Our AML software doesn't capture that activity for analysis. I've heard that recommendation has been made to several other banks in our area so I'm wondering what other banks are doing in this regard. Thanks.

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#2083593 - 06/15/16 06:15 PM Re: Monitor check activity Cher
edAudit Offline
Power Poster
Joined: Jul 2008
Posts: 4,771
You are here
What are they suggesting you to monitor it for?
Opinions can be considered as coming from anywhere but my employer.


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#2083596 - 06/15/16 06:24 PM Re: Monitor check activity Cher
Big Dog Offline
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Big Dog
Joined: Mar 2005
Posts: 2,659
I would request they provide you with information that shows check activity to be considered high risk for money laundering. Most AML systems do not monitor for check activity. Check activity is generally part of fraud systems.

I do recommend that any suspicious activity in and out of accounts be matched to the source/use of funds where appropriate, which could involve checks, but that is not the same as what they appear to be asking for.

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#2083715 - 06/16/16 12:46 PM Re: Monitor check activity Cher
Elwood P. Dowd Offline
10K Club
Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
Our examiner has recommended

If the "recommendation" was made in the written report I've sat through enough regulator panels to know that your bank is not obligated to accept it as direction. You should give it some serious thought and, if you conclude it's a stupid idea that ignores the concept of "risk based" monitoring, make a documented decision not to do it. If it was an undocumented recommendation, just ignore it.
In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.

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