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

How much of this is in your BSA policy already?

Our BSA Policy is almost entirely made up of the cash component. We apparently never have had an anti-moneylaundering "section" or component that addresses other "transactions" under 31 CFR 103.18. We have not set up a "system of internal policies or procedures" to catch "transactions that have no business or apparent lawful purpose, or is not the sort in which a particular customer would normally be expected to engage..etc." To my knowledge ( I took over compliance in July 0f 2002) we have never filed a SAR relating to this type of transaction. The detection on a pro-active basis by the bank of On-going money laundering schemes has never been a priority, but it will be now!

Our shop is in a similar spot. I have proposed procedures that would result in an upgrade to our formerly non-existent AML program, but I appreciate your post outlining the specific areas as a heads up.

We have a BSA/AML system that can help you with this. The system is aggressively priced, can be installed in 30 minutes (or less), and, comes with a 30-day no-questions-asked money-back guarantee. In the last two years, banks have used the system to identify and report more than $160 million in suspicious activity.

We also have an AML policy that fits nicely with our program.

If you'd like more information, please let me know.

Regards,
Wayne Barnett, President
Wayne Barnett Software
A Texas Corporation

877-945-4344
wbarnett@barnettsoftware.com
www.barnettsoftware.com