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#2108412 - 11/22/16 10:56 PM The use of Social Media and EDD
ms.understood Offline
Member
Joined: Jan 2012
Posts: 95
Washington
I was checking in with you all to see what your thoughts (and supporting rules, if applicable) are on using internet searches for EDD on your high risk businesses (Marijuana, TPP, MSB, etc). Do you Google them, and if so, what do you click on? Facebook pages, websites owned by the business, local news articles, etc?

Social media has divided our group a bit; some see it as useful when used to an extent, and some see it as 100% a waste of time. I can see both sides of the coin and wanted more opinions. What if your MRB was advertising an open house where free product was served? Could be a violation in your state, so would you add it to your quarterly SAR? Or do you ignore Facebook like you ignore Wikipedia?

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#2108421 - 11/23/16 09:13 AM Re: The use of Social Media and EDD ms.understood
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,226
Galveston, TX
I can't answer your question, directly. There are pros and cons. However, if you use them, it should be built into your written EDD program and used consistently.
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#2108458 - 11/23/16 02:21 PM Re: The use of Social Media and EDD ms.understood
JacF Offline

Power Poster
Joined: Nov 2001
Posts: 6,719
PA
In many ways, reviewing social media for your business customers is much like reviewing their print advertising, signage, and dropping by their shop. It gives you a picture of what they say they do, and how they operate. This can be very useful information for your EDD.

Quote:
What if your MRB was advertising an open house where free product was served? Could be a violation in your state, so would you add it to your quarterly SAR?

I'm not sure how giving product away for free would be relevant to a SAR. If no money changed hands, the giveaway will never result in activity at the bank.

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#2108532 - 11/23/16 05:01 PM Re: The use of Social Media and EDD ms.understood
bcompliance Offline
Diamond Poster
Joined: Sep 2014
Posts: 1,294
I would suggest using a meta search engine instead of google. That would pull the most relevant search from multiple search engines (google, yahoo, msn, bing,etc.). I have found information using this method that I would have never found simply using google.
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#2108664 - 11/26/16 12:31 AM Re: The use of Social Media and EDD JacF
ms.understood Offline
Member
Joined: Jan 2012
Posts: 95
Washington
In WA state, only certain situations allow for giving away free product, and most of it isn't ok unless you're a medical card holder. That said, we'd care if that marijuana business was our member (customer) because it would be a possible violation of state law, which would go down the path of a Marijuana Priority SAR vs. just a Limited. Does that help?

That's actually where the question originates from....finding things on social media that indicate a possible violation of state law.

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#2108675 - 11/27/16 04:57 AM Re: The use of Social Media and EDD ms.understood
JacF Offline

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Joined: Nov 2001
Posts: 6,719
PA
I understand that the scenario may be a violation of law, but it is outside of the bank's purview. You have no way of ascertaining whether or not the giveaways went to qualified medical card holders, and even if you did, there would be no proceeds from the transaction, therefore no association between this activity and the bank.

It's certainly worthwhile to consider this type of activity in the context of EDD, And it's appropriate to review your customer's banking activity through your EDD filter. But your reporting duty involves only activity that is conducted at or through the bank. At most, the above might be useful background information, depending on the content of your SAR. But the giveaways are not, in and of themselves, reportable activity.

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#2108720 - 11/28/16 04:03 PM Re: The use of Social Media and EDD ms.understood
WonderWoman Offline
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WonderWoman
Joined: Mar 2007
Posts: 2,108
gone fishin'
It's been helpful when I need to do a little deeper dive on someone. But it's not standard. We start with the "Google search" & then go where it leads us.
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#2108733 - 11/28/16 04:38 PM Re: The use of Social Media and EDD JacF
ms.understood Offline
Member
Joined: Jan 2012
Posts: 95
Washington
Originally Posted By JacPCB
I understand that the scenario may be a violation of law, but it is outside of the bank's purview. You have no way of ascertaining whether or not the giveaways went to qualified medical card holders, and even if you did, there would be no proceeds from the transaction, therefore no association between this activity and the bank.

It's certainly worthwhile to consider this type of activity in the context of EDD, And it's appropriate to review your customer's banking activity through your EDD filter. But your reporting duty involves only activity that is conducted at or through the bank. At most, the above might be useful background information, depending on the content of your SAR. But the giveaways are not, in and of themselves, reportable activity.


That's the perspective I was looking to clarify - thanks to all for your opinions!

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#2108764 - 11/28/16 07:24 PM Re: The use of Social Media and EDD ms.understood
Pat Patriot Act Offline
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Pat Patriot Act
Joined: Apr 2009
Posts: 450
Internet searches are crucial - but you should understand WHY you are searching. You should be looking primarily for basic profile data and negative news concerning the customers and any related parties. Occasionally social sites are useful. For instance - does the business have high revenue but lack online reviews? That may cause reson to doubt their source.
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#2109108 - 11/30/16 05:37 PM Re: The use of Social Media and EDD ms.understood
BSA_Jay Offline
Member
BSA_Jay
Joined: Mar 2010
Posts: 72
New York
We conduct web searches for EDD purposes as stated above. We don't have access to social media sites, so we will look for news articles, information about the company, etc, specifically looking for derogatory information.

We also conduct web searches on the vendors of our customers, and more often than not, that's where we've found issues with consistencies in terms of who are customers are paying.

Again we only do that for formal EDD risk assessments and SAR investigations.
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