Monitor check activity

Our examiner has recommended that we expand our monitoring processes to include checks. Our AML software doesn't capture that activity for analysis. I've heard that recommendation has been made to several other banks in our area so I'm wondering what other banks are doing in this regard. Thanks.

What are they suggesting you to monitor it for?

I would request they provide you with information that shows check activity to be considered high risk for money laundering. Most AML systems do not monitor for check activity. Check activity is generally part of fraud systems.

I do recommend that any suspicious activity in and out of accounts be matched to the source/use of funds where appropriate, which could involve checks, but that is not the same as what they appear to be asking for.

If the "recommendation" was made in the written report I've sat through enough regulator panels to know that your bank is not obligated to accept it as direction. You should give it some serious thought and, if you conclude it's a stupid idea that ignores the concept of "risk based" monitoring, make a documented decision not to do it. If it was an undocumented recommendation, just ignore it.