Introductory BSA/AML Examiner School, Providence, RI

Suspicious Activity Monitoring 1. Identification of Unusual Activity Procedure- Transaction ( Manual ) Monitoring: • Review the bank’s transaction monitoring reports. Determine whether the reports capture all areas that pose money laundering or terrorist financing risks. Review the types of monitoring reports used sufficient to capture all areas that pose money laundering and terrorist financing risk?  Currency activity reports  Funds transfer reports  Monetary instruments sales reports  ATM transaction reports  Large item reports  Significant balance change reports  NSF reports  Non-resident alien reports

Suspicious Activity Monitoring

1. Identification of Unusual Activity Procedure- Transaction ( Manual ) Monitoring:

• Determine if the transaction monitoring systems use reasonable filtering criteria whose programming has been independently verified. Do the monitoring systems generate accurate reports? Is the frequency of the reports reasonable?