Reviewing Unusual Activity in Employee Accounts

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Question:

We have a procedure to review unusual activity in employee's accounts on a regular basis. In addition, if we have a suspicion regarding a teller, we have reviewed account activity for that teller. Are there any privacy rules which would restrict our ability to review our employee's account information? Also, is there any consent required by the employee when they begin employment?

Answer:

In the bank, the fact that the account holder is an employee as opposed to Joe XX is of little consequence when using tools to monitor for fraudulent activities. An employee, in a risk profile, is often considered higher risk than a client. The deposit account is the bank’s asset that happens to be an employee’s.

What you normally may find in the Bank is that the entire account base is subject to the same intrusive analysis tools (BSA, OFAC, numerous NSF, kiting trends, ATM activity, neural agent analysis). Employee accounts then would fall to greater analysis based on the necessity to maintain a responsible fiscal condition. For example, a report of every employee account overdrawn, regardless of amount or days o/s or total OD YTD would be created and reviewed. Employees in sensitive areas [wires, finance, Dealer Drafts, Commercial Loans, Item processes, etc] may be subject to account review and "lifestyle" reviews - maybe more.

You should have a written policy in your employee manual that addresses the right of the bank to review employee accounts at any time for any reason, but only by the Cashier, CFO, Compliance Officer or President. When the employee signs off on receiving a copy of the policies and procedures, the employee is also acknowledging the Bank's right to review their account(s).

First published on BankersOnline.com 11/17/03