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The BSA Examiner - Archives

The BSA Examiner is a quarterly newsletter of original content published by Wayne Barnett Software.

2020

Volume 77 – 2nd Quarter

Case #1 – The crops aren’t the only thing dusty.  A BSA officer has to know more than the law. They also must know when a business plan doesn’t sound realistic.
Case #2 – No “fun” in this family’s dysfunction.  A family business strategy that doesn’t make sense should be watched closely. In many instances, transaction coincidence indicates criminal enterprise.

2020

Volume 76 – 1st Quarter

Case #1 – Did I do that? Learn about duplicate check presentment fraud with mobile deposits.
Case #2 – No foundation to build on.  How a contractor obtained advances on a construction loan without authorization. No one was watching.
Case #3 – It has to add-up.  Does your BSA software vendor provide data-validation tests

2019

Volume 75 – 4th Quarter

Case #1 – Not even the price is high.  Is lending money for hemp production a good idea?
Case #2 – The list is growing like a weed.  Serving the cannabis industry can be profitable, but creates extra expense and regulatory scrutiny.
Case #3 – Everything Changes.  The newsletter is going green.

2019

Volume 74 – 3rd Quarter

Case #1 – Up in Smoke.  The pros and cons of banking businesses that grow or sell marijuana.

2019

Volume 73 – 2nd Quarter

Case #1 – This isn’t a shaving nick.  The fraud known as “death by a thousand cuts”.

2019

Volume 72 – 1st Quarter

Case #1 – Pink cowboy boots.  An increasingly common ACH fraud that preys on the lonely.
Case #2 – We’ll give you a hug over the phone.  Be sure you understand the terms of your auto-renewal obligations before you sign the contract.

2018

Volume 71 – 4th Quarter

Case #1 – The devil you know is better.  How do you show the regulators you’re actively looking for significant unexplained changes (SUCs)?
Case #2 – What he said, what they heard.  How do you classify high risk accounts? Hint: it’s not just looking at cash.

2018

Volume 70 – 3rd Quarter

Case #1 – We’ve seen it, we’ve heard it.  What we are hearing about expectations for risk-based AML procedures.

2018

Volume 69 – 2nd Quarter

Case #1 – Things are getting better.  Common questions on the new Customer Due Diligence Requirements (CDDR)  and beneficial ownership rules.

2018

Volume 68 – 1st Quarter

Case #1 – It SUCs if you’re prepared.  What exactly is a significant unexplained change (SUC) and how to you look for it?

2017

Volume 67 – 4th Quarter

Case #1 – It’s not getting any easier.  Federal banking agencies described how their organization intends to implement the Beneficial Ownership rules.
Case #2 – These coins aren’t spare change.  How do you monitor for bitcoin transactions?
Case #3 – Making his list, checking it once.  Should you do FinCEN 314(a) checks on people whose only relationship with your bank is they’re a beneficial owner?

2017

Volume 66 – 3rd Quarter

Case #1 – The rule for 20 years.  Are you required to scan your outgoing ACH transactions for OFAC compliance? Are you sure you want to?
Case #2 – Cheap can be expensive.  Lack of compliance with BSA and AML rules can cost you more for remedial reviews.
Case #3 – You ask, we answer.  We answer  your common questions on the beneficial ownership rules.

2017

Volume 65 – 2nd Quarter

Case #1 – What’s their refund policy?  Common misconceptions on the beneficial ownership rules and risk-based procedures.

2017

Volume 64 – 1st Quarter

Case #1 – Hiding in plain sight.  Does your OFAC system check all the names?
Case #2 – Wishful thinking.  banks that aren’t increasing their BSA budgets are making a mistake.
Case #3 – That was no gentleman.  Do you have a legal obligation to notify your agency when you see someone in authority acting irresponsibly?

2016

Volume 63 – 4th Quarter

Case #1 – Don’t bet on it.  What is your bank is doing to search for unlawful internet gambling (UIG)?
Case #2 – A rough cruise.  A the cashier received commission payments for endorsing software.
Case #3 – A new normal.  Looking at industry-peer analysis.

2016

Volume 62 – 3rd Quarter

Case #1 – No question about it.  An introduction to beneficial ownership, customer relationships and activity monitoring under the Enhanced Due Diligence rules.

2016

Volume 61 – 2nd Quarter

Case #1 – Insult to injury.  How you could be on the hook for ACH transactions that happened months ago.
Case #2 – Cheap and very good.  Criminal services to fraudulently alter a check are inexpensive and easy to obtain, and increasingly causing mobile deposit fraud.

2016

Volume 60 – 1st Quarter

Case #1 – Editors note.  Is your cloud-based virtual server is yours alone? Also, how organized crime uses ISOs (private ATMs) to launder money.
Case #2 – A growing trend.  The burden of stopping account takeovers rests mostly with your bank. Unfortunately, in most cases, bill-pay transactions aren’t available for review until late in the day.

2015

Volume 59 – 4th Quarter

Case #1 – That cloud is a thunderhead. The cloud isn’t near as safe as the they want you to believe.
Case #2 – More knowledge equals less losses.  Finding from a recent white paper on managing losses from DDA charge-offs.
Case #3 – ISO is becoming the new MSB.  What you may be required to do if your bank sponsors Independent Sales Organizations (ISOs)–and even if you don’t.

2015

Volume 58 – 3rd Quarter

Case #1 – Long distance robbery.  Banks are increasingly becoming a victim of DDOS attacks. How you can prepare, and what to do if you are.

2015

Volume 57 – 2nd Quarter

Case #1 – They said what?  How your bank may be liable for fraudulent government benefit payments.
Case #2 – Yes ma’am, it’s the law.  A lot of examiners believe they have a right to see anything retained by a bank. What does the law say?
Case #3 – Mr. EDD.  You have a better chance of finding a “talking horse”, than finding two examiners that agree on what constitutes enhanced due diligence (EDD).

2015

Volume 56 – 1st Quarter

Case #1 – This fish hooks you.  How a man in the middle malware attack, like SuperFish, works, and the risks it poses for your bank.

2014

Volume 55 – 4th Quarter

Case #1 – Bigger losses, smaller victims.  Recent findings from ACH fraud studies showed smaller banks are increasingly targeted.
Case #2 – He seemed like such a nice young man.  Wire fraud involving foreign college students. Be careful allowing wire transfers based on a phone call.

2014

Volume 54 – 3rd Quarter

Case #1 – Starbucks, anyone.  Regulator are strongly encouraging banks to have a BSA system because of missed CTRs. Here’s why.

2014

Volume 53 – 2nd Quarter

Case #1 – A defining moment.  How recent rulings affect the need for rigorous security controls of your internet banking system. 
Case #2 – Sometimes, sorry isn’t enough.  A corporate account takeover could cost you a loss from the fraud–and worse, the loss of a customer.

2014

Volume 52 – 1st Quarter

Case #1 – A little here, a little there … dang, it quickly adds-up.  Read how organized crime used small-dollar counterfeit checks to steal hundreds of thousands of dollars. 
Case #2 – And then, a little bit more.  Fraudulent deposits can also be a source of check fraud.
Case #3 – Half just isn’t enough.  Independent verification reports show most banks still ignore small cash transactions.

2013

Volume 51 – 4th Quarter

Case #1 – Back with a vengeance.

2013

Volume 50 – 3rd Quarter

Case #1 –  Odd dog, new trick.

2013

Volume 49 – 2nd Quarter

Case #1 – Her momma done raised her right.
Case #2 – You know … I thought they looked familiar.

2013

Volume 48 – 1st Quarter

Case #1 – Ok, maybe not so dumb … but don’t bet on it.
Case #2 – CAT tales.

2012

Volume 47 – 4th Quarter

Case #1 – This CAT ain’t cool.

2012

Volume 46 – 3rd Quarter

Case #1 – Dumb and Dumber.

2012

Volume 45 – 2nd Quarter

Case #1 – New Sheriff, new rules.
Case #2 – A little here, a little there.
Case #3 – Ratings made easy (or at least easier).

2012

Volume 44 – 1st Quarter

Case #1 – The future is now.

2011

Volume 43 – 4th Quarter

Case #1 – Not large but painful none the less.
Case #2 – The first loss is the smallest loss.

2011

Volume 42 – 3rd Quarter

Case #1 – Well chosen targets.
Case #2 – It’s what you don’t see that’s most scary.
Case #3 – You’ll never break even.

2011

Volume 41 – 2nd Quarter

Case #1 – Old law, new interpretation.

2011

Volume 40 – 1st Quarter

Case #1 – Tats, piercings and wingtips.
Case #2 – It’s not our fault … no, really, it’s not. (Want to bet?).

2010

Volume 39 – 4th Quarter

This edition of The BSA Examiner focuses on the risks inherent in ACH operations.

2010

Volume 38 – 3rd Quarter

Case #1 – Protection is key … better make that keys.
Case #2 – Revolting in more ways than one.
Case #3 – A fool and his money.

2010

Volume 37 – 2nd Quarter

Case #1 – Clearly visible, cleverly hidden.
Case #2 – Dang Internet.

2010

Volume 36 – 1st Quarter

Case #1 – The bullet they dodged may ricochet back.

2009

Volume 35 – 4th Quarter

Case #1 – Be careful what you DON’T spend.
Case #2 – High risk, low reward.
Case #3 – High risk, low reward #2.

2009

Volume 34 – 3rd Quarter

Case #1 – International ACH Transactions (IATs) are here.
Case #2 – Wild cards.

2009

Volume 33 – 2nd Quarter

Case #1 – Be careful what THEY ask for.
Case #2 – Wanted: dead or alive.
Case #3 – A very happy ending.

2009

Volume 32 – 1st Quarter

Case #1 – The signs are there.
Case #2 – The E doesn’t stand for Easy.
Case #3 – Easier exemptions.

2008

Volume 31 – 4th Quarter

Case #1 –A necessary delay.
Case #2 – It’s all in the numbers.

2008

Volume 30 – 3rd Quarter

Case #1 – Hiding in plain sight
Case #2 – It could be your mother, or mine.
Case #3 – You’re in good company.

2008

Volume 29 – 2nd Quarter

Case #1 – More work and more expense—that’s a FACT.

2008

Volume 28 – 1st Quarter

Case #1 – No one said it would be easy.
Case #2 – A closer look is wise … and required.
Case #3 – No good deed goes unpunished.

2007

Volume 27 – 4th Quarter

Case #1 – Broken slot machine – Part II.
Case #2 – No question about it.
Case #3 – One bank’s trash, another bank’s treasure.

2007

Volume 26 – 3rd Quarter

Case #1 – Paying-out like a broken slot machine.
Case #2 – To close for comfort.

2007

Volume 25 – 2nd Quarter

Case #1 – Do as we say, not as we do.
Case #2 – Don’t blame others for your relationship troubles.
Case #3 – They have to have it, and you have to make sure.

2007

Volume 24 – 1st Quarter

Case #1 – A new measuring stick.
Case #2 – Judgment day.
Case #3 – It ain’t what you think, but it’s suppose to be.

2006

Volume 23 – 4th Quarter

Case #1 – Hidden in plain sight.
Case #2 – So advanced, it’s simple.
Case #3 – Use our list, check it twice.

2006

Volume 22 – 3rd Quarter

Case #1 – More reporting required.
Case #2 – These questions warrant statements.
Case #3 – Easier than you think.

2006

Volume 21 – 2nd Quarter

Case #1 – It’s all in the numbers.
Case #2 – The same, only different.
Case #3 – Now you see it, now you don’t.

2006

Volume 20 – 1st Quarter

Case #1 – Traveling light.
Case #2 – One size does not fit all.
Case #3 – No agreement here.

2005

Volume 19 – 4th Quarter

Case #1 – Good underwriting is no excuse
Case #2 – They aren’t yours, but treat them like they are.
Case #3 – A New Year, a new headache.

2005

Volume 18 – Summer

Case #1 – That’s not a rose you smell.
Case #2 – Seeing what you don’t see.
Case #3 – You don’t have too, unless you say so.

2005

Volume 17 – Spring

Case #1 – Auditing the auditor.
Case #2 – Sign on the dotted line…and they’re not saying please.
Case #3 – The best solutions are simple.

2005

Volume 16 – 1st Quarter

Case #1 – Give them credit, they’re inventive.
Case #2 – MSBs, a few more things to consider.
Case #3 – The light at the end of the tunnel…..is a fast approaching train.

2004

Volume 15 – Fall

Case #1 – We don’t feel your pain, and we hope we never do.
Case #2 – Howdy Sheriff.
Case #3 – Ask for help and make sure you get it.

2004

Volume 14 – Summer

Case #1 – If you think it’s hot now, wait until winter.
Case #2 – Don’t force the issue.
Case #3 – Exception to every rule.

2004

Volume 13 – Spring

Case #1 – Patience expired.
Case #2 – A different shade of blue.
Case #3 – The law hasn’t changed, but expectations have.

2004

Volume 12 – 1st Quarter

Case #1 – Guilty until proven innocent.
Case #2 – Wiring problems.
Case #3 – Spread em’ out.

2003

Volume 11 – Fall

Case #1 – Hanging from the Branches.
Case #2 – We rate with the best.
Case #3 – It’s hard to argue with the numbers.

2003

Volume 10 – Summer

Case #1 – Their hands are tied; don’t let yours get cuffed.
Case #2 – Show us the money.
Case #3 – No partial credit.

2003

Volume 09 – Spring

Case #1 – We sent her to training, so it must be her fault.
Case #2 – You better know it when you see it, and, you better look for it.
Case #3 – You can have him, we don’t want him.

2003

Volume 08 – 1st Quarter

Case #1 – The magic number is eight.
Case #2 – It was good last year. But this year it isn’t enough.
Case #3 – Size does matter.

2002

Volume 07 – Fall

Case #1 – The proof is in the numbers.
Case #2 – It doesn’t say “Annual” for a reason.
Case #3 – Believe it, they’re not joking.

2002

Volume 06 – Summer

Case #1 – Oops, our mistake.
Case #2 – The job’s all yours.
Case #3 – This kite don’t fly.

2002

Volume 05 – Spring

Case #1 – It’s not where you finish, it’s where you start.
Case #2 – Quit your batchin’.
Case #3 – Copy that card.

2002

Volume 04 – 1st Quarter

Case #1 – It’s not just a suggestion, it’s the law.
Case #2 – What they don’t know can hurt you.

2001

Volume 03 – Fall

Case #1 – They’re making the list; you check it twice.
Case #2 – Eight is enough.
Case #3 – It’s all in the numbers.

2001

Volume 02 – Summer

Case #1 – $10 million? Ouch, that had to hurt.
Case #2 – So close, but so far away.

2001

Volume 01 – Spring

Case #1 – Sometime, the usual is unusual. And yes, it is your business.
Case #2 – More money than you need.

Volume 77 – 2nd Quarter

Case #1 – The crops aren’t the only thing dusty.  A BSA officer has to know more than the law. They also must know when a business plan sounds feasible..
Case #2 – No “fun” in this family’s dysfunction.  A family business strategy that doesn’t make sense should be watched closely. In many instances, transaction coincidence indicates criminal enterprise..

Volume 76 – 1st Quarter

Case #1 – Did I do that? Learn about duplicate check presentment fraud with mobile deposits.
Case #2 – No foundation to build on.  How a contractor obtained advances on a construction loan without authorization. No one was watching.
Case #3 – It has to add-up.  Does your BSA software vendor provide data-validation tests

Volume 77 – 2nd Quarter

Case #1 – The crops aren’t the only thing dusty.  A BSA officer has to know more than the law. They also must know when a business plan sounds feasible..
Case #2 – No “fun” in this family’s dysfunction.  A family business strategy that doesn’t make sense should be watched closely. In many instances, transaction coincidence indicates criminal enterprise..

Volume 76 – 1st Quarter

Case #1 – Did I do that? Learn about duplicate check presentment fraud with mobile deposits.
Case #2 – No foundation to build on.  How a contractor obtained advances on a construction loan without authorization. No one was watching.
Case #3 – It has to add-up.  Does your BSA software vendor provide data-validation tests