Skip to content
BOL Conferences
Thread Options
#523979 - 03/29/06 06:39 PM Tracking of Suspicious Wire Activity
Cat Woman Offline
Diamond Poster
Cat Woman
Joined: Sep 2004
Posts: 1,342
New England
Do you track wires for suspicious activity? We have been monitoring cash deposits and withdrawals for suspicious activity for some time, but we recently began doing this for wires. We've been looking at anything $3000 or more and there is a ton of activity. We're wondering what thresholds others are using - maybe we need to raise ours?

Return to Top
BSA/AML/CIP/OFAC Forum
#523980 - 03/29/06 06:54 PM Re: Tracking of Suspicious Wire Activity
Sunshine_101 Offline
100 Club
Sunshine_101
Joined: May 2005
Posts: 127
Wires from the same person to the same person : wires to and from government agencies.
Last edited by Jitterbug; 03/29/06 06:59 PM.
_________________________
The postings on this site are my own and do not necessarily represent my employers opinions.

Return to Top
#523981 - 03/29/06 06:58 PM Re: Tracking of Suspicious Wire Activity
Hrothgar Geiger Offline
10K Club
Hrothgar Geiger
Joined: Jun 2005
Posts: 10,395
Jersey Shore
The thresholds are driven by your particular wire traffic, only the results of your analysis will really tell you how to move your threshold.

That said, suspicious wire activity has attributes beyond the amount.

Are the wires to or from high-risk jurisdictions?
Are they to or from completely unrelated business? (why is a florist getting money from a scrap metal dealer?)
Is it a U.S. business with a foreign bank account?
Do wires out = deposits for that period?
Multiple wires in the same day to the same bene?
Are the wires 'cover payments', or 'for further credit to'?
And 100 other things...

Return to Top
#523982 - 03/29/06 07:00 PM Re: Tracking of Suspicious Wire Activity
tcgcompliance Offline
Junior Member
Joined: Mar 2006
Posts: 32
CA, USA
We review based on dollar amount& geographic point of delivery.

Within the country we review only at $10,000 or more, overseas we review over $5,000. If activity looks suspicious we will then review all wire from or to that client for the past year and if that too looks suspicious we go back still further.
When I started this, about five years ago, I was regularly going back at least the 12 month period on many commercial accounts, because we review regularly the instance of this has got to be less and less.
_________________________
TCG

Return to Top
#523983 - 03/29/06 08:31 PM Re: Tracking of Suspicious Wire Activity
tahdah Offline
Platinum Poster
Joined: Apr 2005
Posts: 932
I think ours was $3000 threshold, but we do have "filters". I'm going to try to remember because I haven't done this lately but we were blessed by the feds. We do both domestic and international wires, very high volume. We picked what we thought were high risk geographies in the US such as border towns, casino towns and cities that have been mentioned in various forums. I think we had 15 to 20. We told the feds we would rotate on a quarterly basis changing to new towns, keeping some of the old. We built into the filter the OFAC sanctioned (the ones that you can do business with for certain dealings, our OFAC filter would catch the rest that are absolutely prohibited). Then we made up a rating system that we put on the report, next to the wire. We assigned a number for the reason, ex. 1 meant sar filed, 2 meant false positive, 3 meant further investigation reveals wire valid, 4 is a Fortune 500 or well known business, we did something similar for a well known customer and so on. I think we had around 8 reasons that we passed the wire. Like I said we passed muster on the way we set this up. It was a pretty labor intensive review. I'm sure there is software or software being developed for wire room use. We did an in-house quick fix, plus my bank is so cheap they would never spend the bucks for a top of the line product.

Return to Top
#523984 - 03/29/06 09:14 PM Re: Tracking of Suspicious Wire Activity
Cat Woman Offline
Diamond Poster
Cat Woman
Joined: Sep 2004
Posts: 1,342
New England
What kind of software are you using? If you don't want to post it, please pm me if you don't mind. We're using an in-house solution but I'm not sure if it's going to give us all of the info that we'd realistically like to have.

Return to Top
#523985 - 03/29/06 09:55 PM Re: Tracking of Suspicious Wire Activity
tahdah Offline
Platinum Poster
Joined: Apr 2005
Posts: 932
For the suspicious activity it's just Access. But some savvy tech people did the programming on our IS or IT area. Like I said my bank doesn't spend the bucks for a products specifically tailored to this if there even is one (don't know).

Return to Top
#523986 - 03/30/06 05:24 PM Re: Tracking of Suspicious Wire Activity
MagicCity Offline

Power Poster
MagicCity
Joined: Apr 2003
Posts: 3,003
Fort Lauderdale, Florida
Even though I have AML Software - it allows me to Export the data to Excel.
Then I sort it by Customer, By Bene, By Wire In and Wire Out, and by Type of Industry... multiple worksheets in the one Excel report and looks for suspicious items that way.

Return to Top

Moderator:  Andy_Z