Suspicious activity: Are you seeing the big picture?
Abstract: Monitoring customer transactions for suspicious activity is a key component of a financial institution’s Bank Secrecy Act / Anti-Money Laundering (BSA/AML) program. Unfortunately, many banks make the mistake of focusing their efforts on deposit accounts and paying less attention to other products and services, particularly lending. This article shows how, after conducting a risk assessment, a bank can design a BSA/AML compliance program that fits its risk profile, and then implement risk-based due diligence procedures to minimize lending-related BSA/AML risks. A sidebar lists several borrower red flags that may raise bank suspicions.