We are a $600 million community bank with 15 branches located in the Northwest. We currently monitor about 100 accounts we consider high-risk for money laundering. All monitoring is done manually. Based on risk, accounts are either monitored monthly, quarterly, semi-annually or annually.
We perfom a customer-based risk assessment on a quarterly basis to identify any new possible high risk accounts. We are looking at software for future monitoring of accounts--the manual process will not work for long.
You're right about regulators questioning the number or SARs filed and accounts identified. Despite major enhancements to our BSA/AML monitoring systems during the past year, we have not seen an increase in SAR filings. To counter this with our regulators we did an in-depth BSA Program risk assessment to show that our size, location, customer base and product offerings make us low to moderate risk for money-laundering--meaning that there wasn't that much activity to catch in the first place. We do the same type of assessment for our customer base and query peers as to their their SAR activity and level of account monitoring.
We are in the middle of a BSA exam and our regulators have felt our self-assessments have been reasonable.
Good luck.
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Preston is a cyberdog