BSA investigation requests to branches

Posted By: NatalieJ BSA

BSA investigation requests to branches - 03/23/22 04:29 PM

Hello everyone and Happy Spring!

I'm looking for input about how you obtain information from your branch staff regarding the source / purpose of funds when a large dollar amount cash deposit or withdrawal is conducted. My goal is to incorporate BSA training to our front line in a more consistent, robust manner. Specifically:

What dollar amount threshold do you use as the trigger for asking for those cash transaction details?

Does your branch staff automatically provide those details to your BSA/Compliance staff when the transaction is processed, or do they wait for a BSA investigation inquiry request to be issued to them?
Posted By: SmallBankBSA

Re: BSA investigation requests to branches - 03/24/22 12:25 PM

I work for a small community bank and I request the branches email me with any deposits / withdrawals of $3,000 cash or more. This may seem low to some but we are a small bank in a rural area.

Some branches are better at it, while some make it seem more of an interrogation and then the customer does not respond. In my training I ask them to just incorporate it into the conversation, "oh are you doing something fun with the money" or "did you win the lottery?" asking silly open ended questions will sometimes get the customer to open up more. then again we do have those customers that basically tell them to pound sand and its none of their business.

If I wait until an investigation is opened the branches typically won't remember why Mr. Smith withdrew $9000 three weeks ago Tuesday. Just MHO.
Posted By: SteveDave

Re: BSA investigation requests to branches - 03/24/22 12:32 PM

It depends on how large of an institution and the technology you have available.

The best system I have made is the core will generate a CTR information screen the teller has to fill out to finish the transaction. It generates in the notes of the account and on the cash report for BSA. BSA completes cash report and uses the notes to fill out CTR. If the notes are off or has a typo something along that nature BSA reaches out to the teller via email with the manager/trainer/teller lead so that inaccuracy can be dealt with by coaching.

We would only take information if we can be certain a CTR is prompted as a customer doesn't need to be bothered until then.

That said my first institution had none of the ability above. I had a cash report and I tried to get the front line to bring the information to me. Core had no notes and no ability to tell if a CTR would trigger. It is close to impossible to get info if front line management is not on board and I spent a lot of time asking for information and our staff consistently had to make calls to get information which made people mad.
Posted By: SteveDave

Re: BSA investigation requests to branches - 03/24/22 12:35 PM


I like the phrase "pound sand". It has been a long time since I have heard it.

Posted By: NatalieJ BSA

Re: BSA investigation requests to branches - 03/24/22 03:15 PM

Thank you very much, SmallBankUSA and SteveDave.

If anyone ever hears of a training session for this specific topic I'd love to know about it. I may need to just write out a script with different scenarios for them to practice and role play so they can get more comfortable with the "Know Your Customer" aspect of the job.
Posted By: mkp122

Re: BSA investigation requests to branches - 03/24/22 05:46 PM

The Branches email us about cash transactions over $7,000 daily.
Posted By: JennKK2

Re: BSA investigation requests to branches - 03/24/22 07:29 PM

such a great question and discussion!

I do get reports daily for cash transactions over $3,000.00. We utilize integrated teller so the CTR pops altering the teller they have to "do something"; but not ask. we have branches and are >$500M however with that being said i truly believe it comes down to training. i would like to think the front line understands the KYC concept but getting anyone to probe or pry or ask in any way seems like asking too much. the younger front line workers i find aren't as comfortable asking (social conversational skills) so that makes the challenge even harder.

i agree that writing up some scripts, role playing, getting them to feel comfortable even saying "so i hope you are going to do something fun!" to the person who took out $9,000.00 is probably the best way. the saying lead by example is long gone as some don't seem to pick up cues in how to chat with customers.
Posted By: Susielou

Re: BSA investigation requests to branches - 03/25/22 04:05 PM

I agree that this is an issue with our younger tellers. They simply are not used to having face to face conversations. Maybe they can text the customer the questions? :-) Seriously though, if anyone has a script they use for training, I would like to use that in our training.