Monitoring High Risk Transactions

An effective BSA/AML compliance program controls risks associated with the institution’s products, services, customers, entities, and geographic locations; therefore, en effective risk assessment should be an ongoing process, not a one-time exercise. Monitoring your risks includes monitoring your transactions, especially your high risk transactions.

Per the FFIEC Manual: The development of the BSA/AML risk assessment generally involves two steps: first, identify the specific risk categories (i.e., products, services, customers, entities, transactions, and geographic locations) unique to the institution: and second, conduct a more detailed analysis of the data identified to better assess the risk within these categories.

Several examples of a system of internal controls will help you document your monitoring program.

• Resources.
• Accessing the data: What are the obstacles? Core system, teller system, BSA monitoring program, etc.
• How did the activity occur? In person, telephone, internet, wire, ATM, or ACH.
• Sample risk assessment for products and services.
• Systems of internal controls.
• Managing Non Resident Aliens.
• Documenting and Monitoring a Cash In and Cash Out Report.

• Financial Officers
• Bank Secrecy Act Officers
• Front Line Staff
• Risk Officers
• Operational Managers

Instructor Profile:

Doug Keipper

Certified Anti-Money Laundering Specialist, Leading Bank

Doug Keipper, is a Certified Anti-Money Laundering Specialist (CAMS) since 2005 and a former Bank Secrecy Act officer and compliance officer for an $800 Million commercial bank in Atlanta before it sold twice in one year. Doug sold BSA software for eight years and has taught anti-money laundering classes since 2008 throughout the southeast and online. He has talked with over 500 BSA officers throughout the USA and Caribbean. He has spent over 20 years in retail banking, wholesale mortgages and financial services