Introductory BSA/AML Examiner School, Providence, RI

Suspicious Activity Monitoring

Transaction Testing (continued): • What monitoring systems are in place to identify unusual activity? • Do procedures address reviewing/evaluating transaction activity for subjects of law enforcement requests (grand jury subpoenas, 314(a) requests or NSLs).

Suspicious Activity Monitoring

1. Identification of Unusual Activity Procedure:

• Review the bank’s monitoring systems and determine how they fit into the overall suspicious activity monitoring and reporting processes. • Complete the appropriate examination procedures for manual or automated systems. • Consider the bank’s overall risk profile, volume of transactions, and adequacy of staffing.