Skip to content
BOL Conferences
Thread Options
#2054813 - 12/17/15 08:36 PM Expected Check Activity
BSAAnonymous Offline
100 Club
Joined: Feb 2012
Posts: 165
Just curious - because I heard this is possibly something come down the pipeline and coincidentally I viewed a webinar which mentioned this - are regulators asking banks to collect "expected check activity" at account opening? Thank you.

Return to Top
BSA/AML/CIP/OFAC Forum
#2054821 - 12/17/15 08:41 PM Re: Expected Check Activity BSAAnonymous
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,371
Galveston, TX
Depends on the risk profile of the customer in most banks.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#2054853 - 12/17/15 09:21 PM Re: Expected Check Activity BSAAnonymous
BSAAnonymous Offline
100 Club
Joined: Feb 2012
Posts: 165
How would you even monitor for such activity? I can see through balance fluctuations or through the course of an investigation, you review checks issued from the account. Is there a AML automated software that would even capture checks paid?

Return to Top
#2054857 - 12/17/15 09:24 PM Re: Expected Check Activity BSAAnonymous
Elwood P. Dowd Offline
10K Club
Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
I assume you are thinking about checks deposited, not checks written...

There has been an unjustifiable amount of "regulatory inflation" in the amount of activity banks are expected to collect at account inception in the name of AML. This information might be very helpful in projecting the need for different products or services; e.g. account analysis, remote deposit capture, etc. but as a facilitator of money laundering? Naaahhhh.

You heard it because somebody said it, not because it was right. wink
_________________________
In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.

Return to Top
#2054859 - 12/17/15 09:33 PM Re: Expected Check Activity BSAAnonymous
Just Jean Offline
Platinum Poster
Joined: Feb 2002
Posts: 582
USA
The FDIC "recommended" that we collect the following at account opening: source of funds, nature of business or occupation, expected activity levels.

Return to Top
#2054879 - 12/17/15 10:17 PM Re: Expected Check Activity BSAAnonymous
BSAAnonymous Offline
100 Club
Joined: Feb 2012
Posts: 165
Thank you all.

Return to Top

Moderator:  Andy_Z