The BSA Examiner is a quarterly newsletter of original content published by Wayne Barnett Software.
2021
Volume 81 – 2nd quarter
Case #1 – Rules and suggestions, you decide. The regulators can’t order a financial institution to buy a BSA system. But they can issue an MRA that can only be resolved with the purchase of a BSA system. We share two stories where this was the case.
Case #1 – Changes are coming, some will be good. Recent changes to federal law will mostly eliminate the beneficial ownership recordkeeping requirements for financial institutions. However, it’s a multi-step process that will take a few years to implement.
Case #1 – It was a moo-ving experience. If you bank originates commercial wires based on the presence of a signature, and you didn’t see the customer sign the request form, your bank is probably breaking the law..
Case #2 – We know it was you … probably. When it comes to commercial wires, the rules for “Proof of authorization” may be more onerous than your bank realizes.
Case #1 – Fried chicken, cooked books. People that own multiple businesses sometimes find creative ways to lower their tax bill, and that’s not always a good thing.
Case #2 – Searching for unlocked potential. A lot of people are looking for a new career or a side-hustle. Sadly, a lot of con men know this and are ready to take advantage of those who are overly trusting.
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.
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?
Case #1 – No question about it. An introduction to beneficial ownership, customer relationships and activity monitoring under the Enhanced Due Diligence rules.
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.
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.
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.
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).
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.
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.
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
