Introductory BSA/AML Examiner School, Atlanta, CA

Funds Transfer Systems Automated Clearing House (ACH) • Use has increased significantly

Roles: originator, ODFI, operator, RDFI, receiver

Risk Factors: • High dollar transactions • Internet transactions • Originated through TPPP • OFAC requirements • Covered payment requirements

Funds Transfer Systems Red Flags: • Volume of transactions on an ACH account – Does it match anticipated activity? – Does the financial institution have documentation for anticipated activity on the account?

• Volume of return items, frequency of duplicate presentment, and customer complaints

• How does management handle over limit occurrences?