When we have multiple small deposits for the same business in one day that total over $10,000, our BSA team is having each branch where the transactions occurred provide conductor information for each deposit, even though none of the deposits total over $10,000 individually. I've challenged this process, and the concern that is raised is that if stop doing this, we will not be able to review activity at the conductor level in the instance the same person couriers deposits for multiple businesses.
I certainly don't want to create a gap in the program, and I think this is a risk-based decision. Is any other bank doing this? Or are we just going above and beyond what is required?