2020 Journal of Community Bank Studies

THIRD PLACE: Mansfield University of Pennsylvania

billion in fines (“Meeting New”). For example, the First National Community Bank of Dunmore, Pennsylvania, was cited $1.5 million in 2015 for failing to file suspicious activity reports that involved illegal funds that were part of a judicial corruption scheme (Hudak). In this situation, the bank was aware of the red flags but purposely did not file reports. FinCEN issued an even larger penalty of $15 million to the First Bank of Delaware in 2012. This bank allegedly conducted inadequate AML measures and aided fraudulent transactions. Even though the bank closed, due to other regulatory problems, before being cited, it was still liable for the penalty. These two examples demonstrate the heavy fines banks may be subject to if found with insufficient policies. Although banks acknowledge that compliance costs are rising, they are fully aware it would be more expensive to risk a heavy fine for not following the regulations. Part III: Technology, Innovation, and Collaboration BSA Software During these times when technology is evolving so rapidly, it is imperative banks use the most up-to-date technology for their BSA/ AML compliance efforts. C&N currently uses BAM+ by Abrigo, a software that prides itself on detecting suspicious activity and giving its customers the best chance of detecting financial crimes.

BAM+ is vital to C&N for a variety of reasons, including its many features that help to automate the BSA compliance process. The software helps to streamline the process of filing CTRs by auto-populating beneficiary and conductor information from previous reports and including an automated risk rating based on C&N’s individual risk tolerances (“Anti-Money Laundering”). BAM+ provides a uniquely tailored software to fit C&N’s individual needs. However, C&N feels that as a whole, all systems could begin to introduce more Artificial Intelligence (AI) into its software. Much of the work being done is still manual, which exhausts the banks’ resources, specifically employees’ time and energy. John Reber reports that employees do 95% of BSA-related work in the back office, while the rest is in the front office. Alerts from the system come out on a set schedule, amounting to

Much of the work being done is still manual, which exhausts the banks’ resources, specifically employees’ time and energy.

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