Monthly structuring report

Posted By: BFrame

Monthly structuring report - 11/16/15 03:11 PM

Good morning,
During a recent external audit, the auditor suggested that I be looking for structuring on a monthly basis (in addition to the daily review that I conduct).

We have no BSA Software, I review reports daily, including the large currency transaction report. This report captures any cash transaction of $8,000 or more. This is the report that I review for structuring. When I see a customer appear on this report, I take a look at the account for any signs of structuring.

For those that may take a "monthly look" for structuring, can you tell me how this report is set up/built?

Thanks in advance for your time.
Posted By: Elwood P. Dowd

Re: Monthly structuring report - 11/16/15 04:29 PM

"The years teach us much which the days never know" is a favorite saying of mine. From my perspective, being able to review customer's cash activity over any extended period is the first goal for an automated system. However, it's a significant undertaking for a manual effort, one I simply would not put in place in the absence of some support for a conclusion that I was missing something.

In an effort to respond to the suggestion, I encourage you to contact your data processing vendor and see if they have suggestions or know of tactics initiated by other users. At the same time, you might select X number of customers who have frequent cash transactions and plot their activity over 30 days to see what you turn up. Documented, both things indicate you took your auditor's suggestion seriously, but that you intended that the decision would be yours based on facts, not the auditor's based on "Oh, by the way..."

"The auditor suggested..." Verbally or in writing?
Posted By: Gioia

Re: Monthly structuring report - 11/16/15 04:47 PM

I can tell you what I do, but it is pretty dependent upon the reports I can run from our teller platform. Weekly, I pull a report of all cash transactions >$1000 and dump into an excel spreadsheet.). From there, I have pivot tables set up so that I can manipulate the data in different ways. I also have different types of conditional formatting set up so that I can see while quickly scrolling through any accounts that I should stop and look at based on frequency of cash transactions. Then I have a tab that pulls out data for accounts that I want to monitor frequently because they are high risk or cash intensive, and I take a closer look at those. I think it works for me right now.
Posted By: CrashDavis

Re: Monthly structuring report - 11/16/15 04:52 PM

On a daily basis, we take the large cash transaction report and list all cash transactions of $3,000 or more and place on a excel spreadsheet and on a monthly I sort this report by customer and look for customers who make frequent cash transactions.

This has worked for me.
Posted By: happyauditor

Re: Monthly structuring report - 11/16/15 05:04 PM

If you have report writing capability, try a report of all cash deposit transactions where there are at least XX number of transactions (for example 2 transactions), the individual cash transaction is at least equal to XX (for example $8,000) and the total for the period (for example, monthly) is at least $10,000.01. Do the same for withdrawals. Adjust the paramters as needed. Ensure you take into account all sources of cash transactions, not just at the teller line, for example, at the ATM as well (if your daily ATM limits are high enough to be in the scope of what you want to review).

Once you fine tune the report you actually might want to run the report daily (or weekly) with a lookback of at least 30 days. This would help you identify the potential structuring timely and you can eliminate the need for your daily review of all one-off cash transactions.
Posted By: happyauditor

Re: Monthly structuring report - 11/16/15 05:10 PM

Ohm, forgot to mention, if you run it daily (or weekly), you would want another crtierion to be that at least one transaction was "new" in the time frame (if running daily, then at least one transaction occured that day, or if running weekly, then at least one transaction occured that week) so as to avoid having the same older data (as a result of the lookback time frame) appear each time you run it.
Posted By: BFrame

Re: Monthly structuring report - 11/16/15 05:38 PM

Ken, I haven't received his report yet. He was here last week. But during the exit interview, he suggested a month look-back.
Although he said, "It looks like you're doing a good job catching the structuring customers, as many of your SARs are for structuring." He didn't find any customer that I should have filed for structuring.
So, to your point, he didn't find that I was missing something.

Thank you for all of your responses. We do have a some report writing capabilities. So I'm hoping to go the route that Happy Auditor mentioned. I'll meet with the report writing "guru" we have at my bank & see what we can accomplish.

Again, thank you.