Introductory BSA AML Examiner School Manual Palm Springs 2019
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
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