Premium Products / Personal Service
Monitoring and Compliance
All BSA systems will help you find transactions that require a CTR. The systems can also be used to file the CTRs electronically. And 20 years ago, that’s all you needed. But things started to change after September 11, 2001–and the changes keep coming. For example:
The use of multiple accounts owned by multiple people, to try and hide the fact that one (1) specific person benefited from the transactions.
The use of ATMs at tribal-owned casinos. (Many of these casinos allow daily ATM withdrawals in excess of $10,000.)
1) The fact that you bank limits ATM withdrawals to $500 per day does not matter. Tribal casinos operate as foreign countries and get to make their own rules.
2) We’ve seen hundreds of daily ATM withdrawals done at tribal casinos, for amounts in excess of $10,000.
The cashing of checks made payable to a small business. The Economic Recovery Act of 2022 makes banks liable for any taxes owed and not paid by a small business, when the bank is deemed complicit in hiding revenues.
Identifying customers who were untruthful about the size of their expected transactions, when they opened their account. The regulators term for this situation is “opened with deception”–or OWD.
We also simplify the creation and filing of SARs and DOEPs.
Note: all forms are kept in the CTM system database, so you’ll no longer have to keep up with FinCEN’s .pdf files.
Our customer risk rating procedure is fast and easy to use. We fully disclose the decision process that results in us identifying activity as suspicious.
It’s not the size of a customer’s transactions that makes then high-risk. Rather, it’s the degree to which a customer’s transactions exceed the bank’s expectations.
Our strategy for predicting a customer’s future activity is based on transaction-averaging and a bank-specified growth factor.
We also have a transaction-smoothing strategy that helps ensure timing differences don’t create an ongoing false-positive finding.
Find out more about the Cash Transaction Monitor
The FBI estimates that in any given year, 41% of U.S. banks with assets below $500 million will have fraud losses exceeding $46,000. Our Suspicious Activity Monitor (SAM) system helps to stack the odds in your favor!
SAM has behavior-modeling logic that alerts you when customers have unusual activity.
We constantly update our systems to search for the latest types of fraud.
Half (or more) of our customers realize savings every year that exceeds the cost of our software.
1) The most common fraud loss in 2022 and year-to-date 2023 is from stolen checks.
2) The most common fraud loss in 2021 was from mobile deposit fraud. (That is, a situation where someone uses the mobile deposit app at two other banks, to twice (2 times) deposit a check drawn on your bank.)
Most banks no longer are concerned about kites. But 20% of our customers find and stop a kite every year
And SAM does a whole lot more. It’s a neat system!
Find out more about the fraud detection capabilities of our Suspicious Activity Monitor
Our Suspicious Activity Monitor (SAM) uses transaction modeling to detect unexpected debit and credit transactions.
First-time commercial debits (that is, a debit sent to a commercial customer by an originator that has never sent a debit to the customer before) are fraudulent 2.4% of the time.
Double-first timers (that is, first time to the customer and first time to the bank) are fraudulent almost 6% of the time.
Unauthorized commercial ACH transactions must be found and returned within two (2) business days of receipt. (Note: Reg E & NACHA’s 60-day rules do not apply to commercial ACH transactions.)
But that’s not all that SAM does.
SAM alerts you to potential corporate account takeovers (CATOs). We have successfully stopped more than $6 million in CATOs.
The system alerts you when customers are dealing with Bitcoin and other digital currencies. This can be critically important for older folks.
SAM reports government benefit payments that may be posted illegally.
It keeps track of returned ACH transactions and gives special attention to unauthorized debits.
The system helps you determine your off-balance sheet ACH risk.
It monitors IATs for OFAC compliance.
And a whole lot more!
Find out more about ACH monitoring using the Suspicious Activity Monitor
Wire Record Keeping
The Wire Transaction Monitor automates all of your wire record keeping, as required by the BSA travel rule.
Wire transactions are imported and maintained in the system database. We work great with Fed and 11 bankers banks/corporate credit unions.
WTM’s daily reports let you monitor all your wires and quickly review the details of any you view as unusual.
Our search features let you focus on specific originators or beneficiaries (even when they have multiple accounts), specific banks and specific countries. This greatly reduces response time for subpoenas and regulatory requests.
Audit downloads greatly simply the wire transfer portion of the OCC’s MLR report.