FDIC examiners have advised us, as part of their current on-site exam in safety and soundess, to develop written procedures for anti-money laundering. They have zeroed in on five areas to be monitored and overviewed by one area or person (that would be me!) to provide coordination. Each area would develop procedures to look for money-laundering, investigate and document actions, and elevate items still "suspicious" to compliance for further review and action. The 5 areas are Currency (BSA-CRT's etc), Cash Vault (Shipments etc), Wires, Business Loans, and Deposit Operations.
Has anybody already come up with templates for the departments listed above? I'm planning on an introductory meeting with department heads and then requesting draft action plans for risk asessment and procedures. I would think that historical data will provide trendlines in some instances, and size and frequency of transactions will play into others. In all cases, my advice to the troops will be- look for any activity which is not consistent with the type of business the customer is engaged in
I'd welcome anybody's thoughts and input. Thanks