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#26054 - 04/05/03 04:36 PM Re: What are you using for online teller systems?
Rubaiyat Offline
Diamond Poster
Joined: Jun 2001
Posts: 1,373
Lido Deck
I've attended a couple of BSA sessions offered recently by our regional OCC office and the real life examples they used were scary. And the issue of missing things below the $3000 mark were exactly some of the issues they were looking at.

Because we had the software written for us we were able to decide what we wanted to track. We do track who purchased the item, who it was going to, which branch was used, dates, addresses, etc. It is now an easy matter to catch a common address on multiple instruments which didn't have common purchasers, or common receivers which didn't have common purchasers, etc.

While it is a separate program from the platform system, it is still easier to use than a paper log. And because it is on the network, it is very easy for our BSA officer to monitor this. The OCC has informally given us their blessing on this process.

Interestingly enough, we had a targeted BSA exam a couple of years ago because of our geographic location. The big guns were here from D.C. and this was not mentioned as an issue. It has only been within the last 18 months or so that this has become hot.
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--A bad day at sea is better than a good day at work.

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eBanking / Technology
#26055 - 04/05/03 04:40 PM Re: What are you using for online teller systems?
Kathleen O. Blanchard Offline

10K Club
Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,277
I agree. This is all post-World Trade Center. AML issues are fast surpassing any BSA specific issues. I am in NJ so it is really a hot button. I am going to push to have the purchase journal used. It is more work for tellers, but it protects the bank.
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Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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