Here are specs for an additional report to pick up both retail and consumer activity. We had our programming folks develop a table for each condition and accounts that had 4 points got reported.
Risk Analysis Checklist
For BSA and AML
1 Customer had $25,000 or more in cash transactions within last 30 days. +1
2 Customer had 5 or more cash transactions > $500 within last 30 days +1
3 Customer had $10,000 or more in cash transactions two of the +1
past three months (rolling months from date of prgm execution -every Sun)
4 Customer had $10,000 or more in cash transactions five of the +1
past six months (rolling months)
5 Customer's account is a consumer (or non-business) account. +1
(Add point if conditions 1, or 2, or 3, or 4, or 7, or 9, or 10, or 12, or
13 are true)
6 Account with the CU is less than one year old +1
(Add point if conditions 1, or 2, or 3, or 4, or 7, or 9, or 10, or 12, or
13 are true)
7 Customer's account has wire activity, cash deposit/withdrawal, +1
& purchase of a monetary instrument within last 30 days
8 Customer has a loan relationship (Taxowner, nontaxowner, or signatory) yes, -1
with CU no, +1
(Add point if conditions 1, or 2, or 3, or 4, or 7, or 9, or 10, or 12, or
13 are true)
9 Customer makes a cash deposit > $500 & withdraws cash the same day +1
10 Customer has incoming or outgoing wires > $10K +1
11 The customer consistently uses the same branch to conduct yes, -1
his business. Less than or = 2 different locations within last 30 days no, +1
(Add point if conditions 1, or 2, or 3, or 4, or 7, or 9, or 10, or 12, or
13 are true)
12 One or more instances in last week where customer made 1
cash deposits to 2 or more related accounts and total of deposits is
between $5K and $10K
13 A review of the member's daily activity shows new Deposits +1
and Wire Transfers on the same day.
14 A review of the customer's daily credit transactions indicate yes, +1
that he is using the account for structuring or sweeps.(# of credit no, -1
transactions (excluding transfers & xdep) exceed 10 in last 30 days
15 Cash deposit over $10K is made that is 150% of average cash deposits 1
made over the last 6 months
16 Purchase of monetary instrument > $3K 1
(Traveler's Checks, Money Orders, Official Checks)
17 Accountholder is a non-resident alien 1
18 Keyword in Account Title or POS/ACH transaction 1
19 Customer's Account is within the category of High Risk Business. Yes, +2
20 Customer's Account is defined as an MSB Yes, +2
21 Customer is a resident or NRA or has out of country address AND has Cash or wire
activity GEQ $3,000 Yes, +4
Scoring:
3 or less - probably not a problem
Accounts with = or > 4 will be added to table for reporting