Thread Options
#2207043 - 02/25/19 08:41 PM Call Back Procedures - Exceptions?
Lele Offline
Platinum Poster
Lele
Joined: Feb 2007
Posts: 827
In the Sun
We are getting a new wire system and in the discussion, a person that has just joined the bank stated that if the customer is not available, they will override the Call back. Say, the customer is heading into a meeting and calls about initiating a wire and because they are a good customer that they 'know' they will override the policy for callbacks. I strongly disagree that there would ever be a reason we would not follow proper procedures especially in these cases because of the risk. The person made the remark the CEO should be allowed to override. I pointed out that situation of, " you can't reach me because I am going into a meeting or catching a plane out of the country' is the classic scam scenario. Feedback, please?
_________________________
Faith is seeing light with your heart when all your eyes see is darkness...

Return to Top
BSA/AML/CIP/OFAC Forum
#2207046 - 02/25/19 08:50 PM Re: Call Back Procedures - Exceptions? Lele
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 79,318
Galveston, TX
Any non-in-person wire transfer is subject to "commercial reasonable" security procedures or the bank is going to be on the hook for any unauthorized wire transfer.

Ask them if they are volunteering to stand in front of the judge and explain how waiving your normal procedures are reasonable (which I am sure are also outlined in your written wire transfer agreement with the company) when the person that they thought ordered the wire said everyone was too busy for a callback. Plus, if you are calling back the person that placed the order - there is no security in that.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#2207050 - 02/25/19 09:08 PM Re: Call Back Procedures - Exceptions? Lele
Lele Offline
Platinum Poster
Lele
Joined: Feb 2007
Posts: 827
In the Sun
We call back to a number that is on the system. Also, we are looking to see if this customer ever sent a wire out. Another thing that was brought out was that if the officer on the account is the only one that has the cell phone number, they could use that. Again, I said 'no'. Callbacks are to use the telephone numbers that are on the system that the customer told us at account opening. I also stated that the customer, at account opening is to keep us informed of any new telephone numbers or changes to their email addresses so we always have the most current information.
_________________________
Faith is seeing light with your heart when all your eyes see is darkness...

Return to Top
#2207054 - 02/25/19 09:11 PM Re: Call Back Procedures - Exceptions? Lele
BrianC Online
Power Poster
BrianC
Joined: Nov 2004
Posts: 6,278
Illinois
Just a warning, callbacks to numbers on the system can be defeated, too. All the bad guys need is to phish the credentials to access the customer's telephone account and they can forward the customer's phone number to a disposable cell phone. Your wire room then receives the call back authorization from the bad guys. Again, the bank will be on the losing end.
_________________________
Sola Gratia, Sola Fides, Sola Scriptura, Solus Christus, Soli Deo Gloria!
www.tcaregs.com

Return to Top
#2207073 - 02/26/19 03:58 AM Re: Call Back Procedures - Exceptions? Lele
JacF Offline

Power Poster
Joined: Nov 2001
Posts: 6,719
PA
Quote:
Another thing that was brought out was that if the officer on the account is the only one that has the cell phone number, they could use that.

I agree with your objection to this idea. One step further- any legitimate contact number for your customers should be in your system. A culture where these types of practices are acceptable, or even normal, is going to look quite attractive to a malicious insider.

Return to Top
#2207080 - 02/26/19 01:41 PM Re: Call Back Procedures - Exceptions? Lele
HappyGilmore Offline
10K Club
Joined: Jun 2004
Posts: 19,487
Pulling people out of the ditc...
we have a requirement for callbacks, we have a procedure for callbacks, we also have an exception process for the RARE instance that a callback will be waived. It takes a VP or higher AND a LOB Executive signature to override the callback. we process over 33k wires per month, last month we had 2 overrides.

I am not in favor of overriding any, but the bank has made a decision and accepts the risk when certain conditions are met.
_________________________
Providing alternative truths since the invention of time

Return to Top
#2207082 - 02/26/19 01:52 PM Re: Call Back Procedures - Exceptions? Lele
ACBbank Online
Power Poster
ACBbank
Joined: Jul 2006
Posts: 4,174
New York City
We have a similar process to Happy. If there is a loss, it's on the P&L of the Executive that approved the override. We don't get many requests for overrides approved.
_________________________
"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
#2207840 - 03/05/19 06:30 PM Re: Call Back Procedures - Exceptions? Lele
chuckchuck Offline
Junior Member
Joined: Apr 2018
Posts: 43
We have had several where the CEO has said "send it" but a persistent bank officer pushed further, only to find out they were a victim of a BEC, or had the instructions switched on them last minute.

I would highly discourage doing any sort of workaround from your callback without having an explicit written agreement that states they understand the risk and will hold the bank harmless.
Even then, Id' probably still have an unacceptable amount that a callback is non-negotiable.

Return to Top
#2207912 - 03/06/19 02:11 PM Re: Call Back Procedures - Exceptions? Lele
1 Peter 5:7 Offline
Diamond Poster
1 Peter 5:7
Joined: Jun 2001
Posts: 1,339
TX
In a prior bank life, I saw a real-life 6 figure loss occur because call-back procedures were weak or not followed as others have described above. The loss was unrecoverable. Careers were affected.
_________________________
Opinions are mine not my employer's, and should not be taken as legal advice.

Return to Top

Moderator:  Andy_Z