BSA/AML Examiner School - Case Study Oct 2023

LCB12115

Transaction Testing Checklist 6.3: Suspicious Activity Monitoring System

Account Name

Date Account Opened

1

XXXXX

10/17/2014

1

Review the selected accounts for unusual activity. For any unusual activity, is the activity typical for the customer (i.e., the sort of activity in which the customer is normally expected to engage)? When reviewing for unusual activity, consider the following: • For individual customers, whether the activity is consistent with CDD information (e.g., occupation, expected account activity and sources of funds and wealth). • For business customers, whether the activity is consistent with CDD information (e.g., type of business, size, location, and target market). For each customer found to have unusual activity, answer the following: Did the institution's manual or automated suspicious activity monitoring system detect the activity that was identified in the previous procedure as unusual? For transactions that were identified as unusual, discuss the transactions with management. Did the account officer demonstrate knowledge of the customer and the unusual transactions? After examining the available facts, does management know of a reasonable explanation for the transactions? N Comments: This sample was taken from the Bank's High Risk list. Account statements for September through November 2015 were reviewed. Activity on the accounts appears normal; no unusual or suspicious activity was identified. NA NA y NA NA NA Has the institution failed to identify any reportable suspicious activity?

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