ACH Report for BSA Purposes

Does anyone in BSA review any type of ACH report? We have Examiners in house and they are asking us if we have a report that we review for ACH purposes, the same way we have reports for wire activity, loans secured by cash, etc. If you do, can you share with me the parameters of what you look for. Thank you.

Just my opinion, but ACH reports by themselves don't serve much purposes for AML. ACH activity would typically be used in the layering phase and without knowing the origin/destination of the funds, I'm not sure of the purpose? We will always review ACH activity during KYC reviews or during a review of an account flagged by our transactional monitoring system.

If you have a lot of IAT activity, it might be worth reviewing based on what jurisdictions you consider to be high risk (similar to wires).

Agree with ACBbank. The ACH activity report by itself doesn't tell you a whole lot. We feed it into our BSA/AML software and produce a series of reports at the end of each month. Some of those reports will indicate international ACH activity, ACH activity followed by cash withdrawals, ACHs to tax havens, ACH activity over certain numbers, amounts and percentages (e.g., ACH spike) that might lead us to perform further investigation. We also can isolate the IATs (which to date have been few, all Paypal, all for small amounts for merchandise coming out of Asia.

Also, if your customer originates ACH you should be interested in returns and return rates as they could be an indicator of fraud. High vlumes of ACH with other entity names could also indicate a TPPP.

You can also do key word searches of ACH activity to monitor or identify if your customers are involved with illegal internet gambling or if they now have a privately owned ATM on premises, conduct MSB activity, etc...

Hello,quick question in regards to ACH's. Becomming an Accredited ACH Professional (APP), does it help for a BSA analyst to increase his/her salary? I know about the CAMS will defenitely do, but I'm curious anyway if it will. Also, I'm interested in learning more about the ACH industry as well.

I would speculate that on your current job, this would depend on your supervisor/manager and your bank's compensation structure. This would be true of any form of certification. Some firms stress the importance of continuing education and do reward those who pursue additional certifications. Some may either not care or need to be educated as to how it increases your value to them in doing your job (always relate it back to the job).

Certainly it's a good line item for your resume that can use in job hunting and may increase your potential for more money.

Does anyone know of any ACH key word searches I can perform to identify possible TPPPs?

I'd also be interested in any keywords I could use to search for internet gambling (a recent auditor recommendation).

If the auditor made such a recommendation without supplying you with the recommended search criteria, then I would tell them thanks and move on. It is a vacuous recommendation.

We just had a state examiner recommend reports for various volume considerations...ACH was one of them, new accounts was another.

volume consideration??

You mean to help you establish your organization level or customer level risk?

Looking at our Risk Assessment, incorporating volumes of each type of listed transaction (ACH, Wires, etc) or new accounts by volume to help understand risk from that standpoint.

Well that makes sense, but that is far removed from the key word searches that were being discussed.

After looking up "vacuous," I agree with rlcarey's response. For decades I've bristled at examiner recommendations that purely indicated they could not find anything of substance. Now, auditors are apparently facing the same dilemma and responding in the same way. My two most recent favorites:

* The bank needs documentation for the percentage of revenues an exempt customer derives from ineligible activities. (There really is no "pat" way to do that and it would require deposit customers to provide information regarding income that some borrowers balk at providing. I'd rescind the exemption instead.)
* The bank should begin identifying beneficial owners of all entity customers. (The requirements should be added to it's CIP.) If the ABA spends 27 pages analyzing FinCEN's proposal as [censored] I don't see the wisdom of adopting it voluntarily. In addition, it falls under CDD, not CIP.

If a bank finds its auditor's recommendation vacuous it should first respond in writing to that effect and second, start looking for a new auditor.