Compliance Officer Employee Account Access

Posted By: Anonymous

Compliance Officer Employee Account Access - 07/06/22 07:00 PM

What level of access does your Compliance Officer have to employee accounts?
Posted By: M Cockrell

Re: Compliance Officer Employee Account Access - 07/06/22 07:07 PM

Zero. Told "We let external auditors handle employee accounts."
Posted By: HappyGilmore

Re: Compliance Officer Employee Account Access - 07/06/22 08:15 PM

access to employee accounts is on a business need, compliance officer does not fall into the business need category
Posted By: Rocky P

Re: Compliance Officer Employee Account Access - 07/06/22 08:51 PM

In a smaller bank, I had access as auditor, not as compliance officer. Also, could not let any staff review the statements, and the report was solely to the audit committee in private session.
Posted By: InFairness, CRCM

Re: Compliance Officer Employee Account Access - 07/06/22 08:56 PM

Limited access for compliance monitoring. Usually income is redacted for employee privacy.
Posted By: SmallBankBSA

Re: Compliance Officer Employee Account Access - 07/07/22 12:41 PM

Is your Compliance Officer responsible for BSA duties as well? Then I can see having access to employee accounts if that is the case for monitoring purposes as InFairness stated.
Posted By: Anonymous

Re: Compliance Officer Employee Account Access - 07/08/22 01:38 PM

Different Anon here, I'm Compliance and BSA. I have access to Employee Accounts. I review for insider abuse, BSA, etc. It's totally going to depend on the depth, size and complexity of your institution.
Posted By: InFairness, CRCM

Re: Compliance Officer Employee Account Access - 07/08/22 05:35 PM

Originally Posted by SmallBankBSA
Is your Compliance Officer responsible for BSA duties as well? Then I can see having access to employee accounts if that is the case for monitoring purposes as InFairness stated.

I don't have BSA duties. Our BSA officer also has limited access for monitoring purposes. My team looks at insider abuse, own-account transactions, etc.
Posted By: JWills, CRCM

Re: Compliance Officer Employee Account Access - 07/08/22 08:01 PM

I'm compliance, and have no access to employee accounts. When information is requested by auditors or examiners, our VP of HR will provide that information directly to them.
Posted By: ACBbank

Re: Compliance Officer Employee Account Access - 07/11/22 09:50 PM

Compliance means different things for different banks. At my place compliance is regulation compliance and does not have access to insiders. I am the BSA Officer and I do have access for monitoring purposes. We have had employees generate alerts in the past and it occasionally still happens.

Legal can and does monitor for personnel attempting to access employee accounts to make sure any access is for business purposes. External audit does reviews during the appropriate audits as well.
Posted By: Anonymous

Re: Compliance Officer Employee Account Access - 07/13/22 01:39 PM

THIS IS WHY YOU DO NOT BANK WHERE YOU WORK.

Then there's no need for ANYONE to look into your account for any "business need".
Posted By: Rocky P

Re: Compliance Officer Employee Account Access - 07/13/22 02:54 PM

Anon, politely disagree.
As auditor, the audit program was to check for multiple deposits (same day >3), more than 12 statement deposits excluding pay and interest, and deposits that would trigger a CTR. Concerns with someone with access to accounts [stupidly] putting money into their oen account.
Posted By: SmallBankBSA

Re: Compliance Officer Employee Account Access - 07/13/22 04:06 PM

Anon, I do agree about not banking where you work. I keep a small mad money account at my bank but keep my every day account with another institution.

Years ago (early 2000s), I worked for a different bank and I recall one member of the department that would look into others accounts to see pay, where they spent their money etc etc. We had access for investigation purposes at that time. I left there several years ago but prior to leaving I do recall they put a control in place for accessing employee accounts.
Posted By: HappyGilmore

Re: Compliance Officer Employee Account Access - 07/13/22 05:42 PM

Originally Posted by Anonymous
THIS IS WHY YOU DO NOT BANK WHERE YOU WORK.

Then there's no need for ANYONE to look into your account for any "business need".

except, of course, when the employee wants to cash a check and you want to make sure there are sufficient funds in the account.
or when a bank employee perhaps has a garnishment or levy placed on their account. or it appears they are mishandling client funds and depositing to their own. or covering NSF items or waiving fees (yes, not all banks have something in place to keep an employee from making changes to their own account). or the bank receives a subpoena on an employee account and they must take action to provide information.

essentially, any reason you would need to look into a non-bank employee customer's account, you would have the same business need for bank employee accounts as well. but that access should be restricted to a business need only, and the bank should also have a report that shows who accessed employee accounts and should be reviewed. just looking to see what is happening is not a business need.
Posted By: Anonymous

Re: Compliance Officer Employee Account Access - 07/13/22 05:45 PM

Originally Posted by SmallBankBSA
Anon, I do agree about not banking where you work. I keep a small mad money account at my bank but keep my every day account with another institution.

Years ago (early 2000s), I worked for a different bank and I recall one member of the department that would look into others accounts to see pay, where they spent their money etc etc. We had access for investigation purposes at that time. I left there several years ago but prior to leaving I do recall they put a control in place for accessing employee accounts.

This was my anon post, and thank you. Some years ago, I worked for a small bank, where I also had my primary checking account. Some friends and I went out drankin' on a Saturday night and I ended up writing 4 or 5 checks to the bar where we were indulging (can you even imagine writing a check at a bar these days?). Anyway, somehow these checks were deemed "suspicious" by a superior of mine, who brought me in their office and wanted to know why I was writing so many checks to one "business". I can't for the life of me recall what excuse I used, but without a doubt, I promptly closed my account and opened it at the bank across the street. I'll tell a stranger anything they want to know, but I'll be da#med if I'm explaining to my coworkers where I go on my off time.