Our bank has a trust department. Historically, we've only brought CIF info on the trust accounts into our AML solution for OFAC and 314a scans. We are replacing our current AML solution with a more robust solution, and in the process we are planning to map transactional data from all the bank's transactional systems (deposit core, trust, leasing, investment, etc...). We've received some criticism in the past from our examiner (OCC) because we didn't have an "enterprise" AML monitoring program based on us not bringing in transactions from non-core applications. Now we are getting significant push-back from our trust group. They flat-out said they don't want the BSA group monitoring their customer's transactions (they said they do a fine job of it internally within the trust group.....they don't need us, thank you very much). How many other banks out there are monitoring trust transactions centrally, and has anyone seen a trust group that adverse to having their customer's transactions monitored?

There are confidentiality issues when you work with trust accounts (personal and institutional trust accounts alike), and that may be where the hesitation comes from with your Trust department staff.

How is your Trust department's process for reviewing transaction activity and detecting suspicous activity? Does it have proper policy and procedure in place? If so, and if it appears to work, you may not have an issue.

My bank's trust area handles its own BSA monitoring; however, bankwide monitoring is performed by our Financial Intelligence Unit for the bank's identified high risk customers. These high risk customers are reviewed on an annual basis and the review includes all accounts and relationships across all lines of business and ends with a multi-page report/conclusion.

Without knowing how complex and how large your institution is, it is difficult to know what sort of advice to give, but hopefully what I've written will give you a little insight to the issue (personally, I work in the institutional trust area or a large bank).

I forgot to mention, this process is working well for us and has a thumbs up from the OCC so far, which says a lot considering the regulatory BSA scrutiny we are under right now...