I'm a newbie to the board, so take it easy on me . . .

We were criticized in our exam for not doing enough to review wires for suspicious activity. We review for OFAC and FATF countries and look for cash tranasactions made in close proximity to sending or receiving a wire. We also look for wire activity associated with anyone we've identified as a high-risk customer.

Any ideas on what else we can do in a manual environment (software is coming after the first of the year).

Thanks for the input.

I have had our wire department enter all wire info onto an excel spreadsheet. I can access that spreadsheet and use the sort function to look for patterns/trends by originator, beneficiary, etc.

We also have an extract into an Excel spreadsheet until next year. We sort by Originator, Beneficiary, and TIN. We also look closely at how recently the account was opened before it started wire activity and wires in/out for the similar amounts on the same or next day..

Excel is a reasonable choice since you can quickly sort by originating party and beneficiary party. (Putting them in Access will also let you search on name similarities.)
Among the patterns to consider:
So-called 'exclusive relationships': one party wiring repetitively to another.
Single originator to multiple beneficiaries.
Multiple originators to a single beneficiary.
(Note: in special cases 'single' might really be 2 or 3).
Multiple wires on the same day.
Wires on consecutive days.
Wires with no discernable business reason (a seed company wires large amounts of money to a used car dealer.)
Originating party and originating bank in two different countries. (and bene party/bene bank in different countries.)
Bank-to-bank covers of customer payments.
I have some 'pet' country-hop patterns that I play with as well.

These are not necessarily evidence of wrongdoing, but they will get me to ask further questions and do further research.

Does this help?

Nice post, AML.

KC, you should also look at the destinations in terms of "high risk," in terms of U.S. as well as foreign geographies. Identifying HIFCAs is relatively easy. Identifying HIDTAs is more difficult and I would probably make the attempt only on recurring destinations rather than one-off transactions.

You can make a career out of sorting wires and still find nothing. First of all, focus on whether the wire is legitimately explained by the customer's business activity and then spend your blood and treasure on those where the answer is not so clear.

I totally agree with you Ken! Looking at wire activity on a spreadsheet is one piece of the puzzle, but buisness names are not always reflective of the business type. The person conducting the review must inquire with the branch of account as to the nature of the business to determine if the transactions make sense.

IMHO, reviewing wires is a challenge even with a good AML software program. It is very important that branch employees are well trained to detect ususual or suspicious wire activity.

Depending on your volume, I, as the BSA Officer, review the wire transfer logs daily. Attached to these logs are the actual transmittal records for further detail (both outgoing and Fedline printouts). Now we only average about 15 wires/day so it's not that cumbersome. If you've got a much higher volume, this method may not work.