Thread Starter: ColoradoAML
Title: Re: The stupid ways that BSA math works
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The current instructions appear to have changed that guidance.
Item *29 Amount involved in this report: Enter the total amount involved in the suspicious activity for the time period of this report. Multiple amounts will be aggregated and the total recorded in Item 29. This requirement applies even when the amounts involve different transaction types, such as when some are deposits and some are withdrawals. All amounts are aggregated and recorded as the total amount.
We have always followed the same process Rockchucker described in their first post. If related credits and debits are suspicious, we aggregate them. For example, a customer receives fraudulent $100k wire and sends the $100k to an accomplice, the amount would be $200k. On the contrary, if a customer requests a $100k disbursement from their retirement account in order to pay that $100k out to a criminal, we may describe the circumstances of the disbursement but not consider it suspicious and file on only $100k.
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