BSA/AML Student Exercises Dec. 2022

LCB12/15

Checklist 6.1: Suspicious Activity Report (cont.)

Yes No

N/A

 Has the programming of the methodology been independently validated?  Are there established controls to ensure limited access to the monitoring system and sufficient oversight of assumption changes? Review a sample of customer activity. After reviewing the samples, answer the following:  Does the manual or automated suspicious activity monitoring system effectively detect unusual or suspicious activity?  Identify the underlying cause of any deficiencies in the monitoring systems (e.g., inappropriate filters, insufficient risk assessment, or inadequate decision-making) in the "Comments" section below.

NA

NA

Y

NA

Comments: Account Monitoring - The Bank currently uses manual processes to monitor suspicious activity. Reports include #393 Large cash items >-= $3K, #504 DDA Accounts Suspected of Kiting and #508 DDA Significant Balance Change Report. The reports are reviewed on a daily basis. 42

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