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Establishing a Kiting Pattern

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It is my understanding that a ninety day review is required to establish a true kiting pattern. Is this a BSA or industry requirement?

It's not a requirement at all. It's a suggestion that you'll need to review at least three month's activity to confirm the existence of a kite and have a good idea of the transaction patterns involved. However, if you suspect a kite in process based on recent transaction history, you shouldn't wait until three months' activity has piled up before taking decisive action to protect your bank from loss.

First published on 12/13/10

First published on 12/13/2010

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