BSA/AML Examiner School - December 2022

12/1/2022

Example 4: Bobbie Dayton opened his account online, has never been into the banking center, and told the credit union that he was disabled and would be getting social security. Since December 15th he has made $8,998 in deposits and $6,971 in withdraws. He has never had a social security deposit. December 15th, he made a $2,800 shared branch check deposit at XX Bank in Springfield, Ct. The next day he had trial deposits coming into his account from YY Bank. On December 27th he made a mobile deposit for $900.00 and withdrew a check from home banking for $3,400. January 2 the mobile deposit came back as NSF. January 2nd, we placed a stop payment on the home banking check he withdrew and then same day he did multiple ATM branch deposit again at XX Bank. The next day he did a cash withdraw at the ATM in Springfield, Ct. He is now having trial deposits from YY Bank and ZZ Bank.

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Example 5: I was notified by staff from the Virginia Branch that a member was making cash deposits out of her usual deposit pattern. It has continued that she is coming into the Virginia branch and making large cash deposits the same day or next day using a cash app to send the money back out of the account. Looking at the transactions she is occasionally keeping a small amount of the funds. Listed below is a list of the cash transactions activity in and out. I will continue to monitor this member’s activity. Sept 16, 2019- in- 1,200 Sept 21, 2019- in- 700 Oct 2, 2019- out- 900 Sept 17, 2019- out- 1,200 Sept 25, 2019- out- 2,100 Oct 4, 2019-in- 1,900 Sept 17, 2019- in- 1,700 Sept 25, 2019- in- 1,300 Oct 5, 2019- out 1,900 Sept 18, 2019- out- 1,800 Oct 1, 2019- out- 1,300 Oct 8, 2019- in- 2,100 Sept 21, 2019- out- 1,100 Oct 1, 2019- in- 1,000

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