Monitoring Monetary Instrments

We do not have an automated solution for this yet. As such, on a quarterly basis our BSA group does a scrub of the MIL to identify any individual that may have purchased more than one MI in the preceeding quarter. If they find any then they send to the AML group who will conduct an investigation.

This is a decent enough process to cover the gap until we can implement automated monitoring. However, it imposes some interesting production constraints.

Firstly, because these are cash purcahses there are invariably never any "alerted" accounts to investigate. As such, we end up doing an investigation of every account tied to the customer, which ultimately end up 99% of the time as a No SAR.

Does anyone have any suggestions on how to modify the language of our procedure (generalized above) or any processes that we could implement to still have a good review process but not bog down production with what has proven to be a useless process?

I was thinking of focusing solely on sequentially ordered monetary instrument purchases who aggregate exceeded $5,000.

Start by figuring out what sorts of behavior you're trying to detect. If it's structuring, or excessive unexplained use of cash MIL purchases, focus more on clusters of transactions by the same person within several days or a week. Chasing down particulars on someone who's bought two checks in 3 months seems to me to be overkill and a terrific example of spinning your wheels.

In my prior bank we were able to drop a list of cash purchases over various periods of time from our teller system. Examiners were satisfied if we could demonstrate our periodic review of checks sold over a 6 month period. It only took a few minutes to drop the list, mark up to demonstrate review (including pulling checks if anything appeared unusual) and file away.

The report could be sorted in different ways, customer name, amount, etc. I would usually pull in several ways as further evidence of a diligent review.