I'm using new AML software rules for incoming from same source. Student (23) at local private college ($$$). Gets money sent in by ACH from 'IGMPay", to the tune of $33,000. per month average. Yes, you read the amount right. He cashs a few checks, but mostly debit card type purchases but also an occasional check to himself, for several thousand at a time. I know that there are very wealthy people with major bucks and they throw their money at their kids...also kids have major trust accounts. Now, I have this account flagged from the rules for the reason mentioned above - multiple incoming from same source. Just how much should this type of account be monitored? What else to do? Opened in 2004 and the credits started right off ($27, 000. the first month) The amounts come in multiples of $3,000. that is over several days in a row, always $3,000. exact). Opinions please.

IGM-Pay is a payment processor for internet gambling sites, and is located in Gibraltar.

From the sound of it, I'd want to know if this kid is a)running an internet casino site, or b)a farm of sites referring surfers to other internet casinos. It's not exactly the most legal activity in the world.

You'll have to get information from the kid him/herself, since Gibraltar is something of a bank-secrecy haven and probably won't tell you squat.

Just my US$.02

put this customer on your list of high risk customers and monitor ita ccording to your policies (evey 6 months of whatever you do). as long as you can prove ongoing monitoring and due diligence, you shoudl be ok.

Based on what has been said so far, I would file a SAR and close the account. Internet gambling is illegal, such large activity in an account of this nature is not "normal and expected", etc. This is coming from someone who does not file many definsive SARs (I think).

Trees,

Before we get all frisky with the SAR filing and account closing... Was there any investigation on the source of the funds being deposited? Is the enhanced monitoring the first step in your process? What source of funds was given when the account was opened?

My gut feeling is that this is internet gambling, but until you do an investigation, you won't know....

1st dep. was $2,000. cash. 25 days later was an out of town check p/o cust. for $5,000. A couple small checks to locals (maybe rent?) the, 3 months later the ACHs started coming in $18,000. during the first month. All from IGM Pay. Is there someplace i can confirm IGM is the internet gambling source? I need to build my file. As the initial deposits were rather plain vanilla, there was nothing to peak EDD.

I went onto Google and put in iGM Pay - and when I tried to click on the link I got a big "Surf Control" sign so I'll probably be fired <grin>. Do what I did and see what you find. It said on the intro that when you enter you could begin to play their games immediately. Good luck!

I would definetively conduct an in-depth investigation on ALL the activity of the account and any other related relationships. I would contact the customer (with a customer service approach) to find out more details about the source of the funds and purpose of such activity. I would contact IGM to get as much info as possible.
Lastly, the most important aspect of the investigation DOCUMENT,DOCUMENT,DOCUMENT....
Hopefully, based on the findings you'll have a better picture and decide if a SAR is granted or just continue with the Ongoing monitoring. This process will likely demostrate to regulators your Due diligence approach.

Hmmm... it appears to be a small competitor to PayPal:

http://www.igmpaywallet.com/index.html

They certainly seem to have a bulk business in sending on-line casino winnings.

I don't think this is an open and shut "File a SAR/close the account" case. IMHO, someone from your bank needs to contact this customer and ask the Due Diligence questions. Further action would depend in the answers and if they answers can be verified.

$33 Thousand a month coming into an account of a student from a dubious source such as IGMPay? What could he possible tell the bank to allay the bank's suspicions?

I've been keeping my eye on a very similar situation and while I find it suspicious, I still haven't been able to figure out quite what is going on. Same scenario with a student account with thousands of dollars per month churning through via ACH from sites that I *believe* to be related to gambling. But I haven't found specific cause for any action yet.