Introductory BSA/AML Examiner School, Atlanta, CA

Funds Transfer Systems

Risk Factors

• Number & dollar volume

• Geographic location

• Customer versus non-customer

• Lack of formal recordkeeping (IVTS)

• Minimal identifying information (PUPID)

• Eliminates face-to-face interaction (RDC)

Funds Transfer Systems

Risk Mitigation

• Customer Due Diligence

– Type & size of business

– Customer expectations

– Historical customer activity

– Activity of similar customers

• Suspicious Activity Monitoring System