Introductory BSA AML Examiner School Manual Palm Springs 2019

MSBs Can Help Fight Money Laundering

What Should MSBs Look For? (Cont.) Rapid increase in size and frequency of cash used by a particular customer. Employees Watch out for employee behavior, such as: An MSB employee whose lifestyle cannot be supported by his/her salary, which may indicate receipt of tips or bribes. An employee who is reluctant to take a vacation, which may indicate he/she has agreed, or is being forced, to provide services to one or more customers in violation of law or company policy. An employee who is associated with unusually large numbers of transactions ■ ■ ■ ■

to provide services to one or more customers in violation of law or company policy.

Situations like those described in this section often will be found, upon further examination, to be completely legitimate. By the same token, other situations not mentioned here might be suspicious if they are inconsistent with the normal activity of a particular customer or employee. As an MSB or MSB employee, you must make a reasonable judgement.

or transactions in unusually large amounts, which may indicate he/ she has agreed, or is being forced,

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