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#1331722 - 01/27/10 02:51 PM Rule based AML programs-how frequent??
Trees Offline
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Joined: Apr 2005
Posts: 4,013
We use patriot Officer with all those nice rules. I would be interested in hearing from PO users as well as other AML program users where rules are used to identify potential SARABle offenses. Specifically, are you running rules only once permonth or once per quarter? Do you have different rules that you run daily or weekly and then another set that you run monthly and/or quarterly? Thanks!!

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#1331742 - 01/27/10 03:00 PM Re: Rule based AML programs-how frequent?? Trees
#Just Jay Offline
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#Just Jay
Joined: Oct 2006
Posts: 14,390
Cheeseheadland
We run all rule scenarios every two weeks.
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#1332069 - 01/27/10 05:52 PM Re: Rule based AML programs-how frequent?? #Just Jay
Trees Offline
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Joined: Apr 2005
Posts: 4,013
Just jay, how many rules are you talking about??

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#1332238 - 01/27/10 08:02 PM Re: Rule based AML programs-how frequent?? Trees
#Just Jay Offline
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#Just Jay
Joined: Oct 2006
Posts: 14,390
Cheeseheadland
Right now 7, but I really need to get in there an re-evaluate them adn create some more.
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#1332440 - 01/27/10 10:06 PM Re: Rule based AML programs-how frequent?? #Just Jay
devsfan Offline
Diamond Poster
Joined: Jun 2004
Posts: 1,927
NYC
We have 15 reports and run them monthly. We get 300-400 hits so could not run them any more frequently.

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#1332546 - 01/28/10 12:07 AM Re: Rule based AML programs-how frequent?? devsfan
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 85,401
Galveston, TX
There is no right answer and whatever frequency you use should be supported in your risk assessment. If you hardly ever identify SAR through your reports, then quarterly might be acceptable (or your rules are too lax).
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#1332740 - 01/28/10 03:12 PM Re: Rule based AML programs-how frequent?? rlcarey
Trees Offline
Power Poster
Joined: Apr 2005
Posts: 4,013
Good points everyone. What I am focusing on is whether or not it has become some kind of best practice among most banks to run certain rules more frequently than once per month or quarter. For example ACH (due to increase in ACH fraud) and wires. Both represent quick funds movement as well. I was getting the feeling that banks are using the rules based AML software to produce reports on a more frequent basis, say weekly or every daily for these types of products. I am sure we have all risk rated these products medium or high in light of recent fraud. Would still like to know what other banks feel about this, that is, more frequent review to detect whether or not fraud has been perpetrated....

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#1332753 - 01/28/10 03:17 PM Re: Rule based AML programs-how frequent?? Trees
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
Most banks I see when doing BSA audits are running rules once or twice a month. Large banks with large staff can afford to run more frequently.

You might get ACH/wire reports off of those systems as well as your rules which can also alert you to unusual activity.


Some systems have a default daily but that is difficult for a community bank to deal with and the vendor acknowledges that many clients change that to 1 or 2 times a month. You could always set up a particular rule to run daily if you chose.
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#1333192 - 01/28/10 07:31 PM Re: Rule based AML programs-how frequent?? Kathleen O. Blanchard
NewTooBSA Offline
Platinum Poster
Joined: Nov 2005
Posts: 568
Texas
We are a PO user and run the rules monthly. Under the SAR section, we have 334 rules to monitor for cash, ach, wires, atm, check activity and identity theft scenarios. This also includes rules for monitoring wires to specific high risk countries and separate rules for business, individual and foreign customers.

We also have an additional 38 rules for money transfer monitoring that is run monthly. These scenarios are looking at the flow of funds and look at the activity differently than under the SAR module.

There are daily reports available that can be run on a specific type of transaction. If you feel that monthly reporting is not sufficient, choose which high risk categories you want to monitor more frequently and run just those rules as frequent as you want. After you have done this for a few months and feel more comfortable with the results, you can discontinue this by documenting your results and why it is no longer necessary.

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#1333280 - 01/28/10 08:37 PM Re: Rule based AML programs-how frequent?? NewTooBSA
DebL Offline
Gold Star
Joined: Jan 2007
Posts: 314
CA
Patriot Officer has a user forum where this topic was recently covered. (UCEN)

If you aren't already a member, you should go check it out.
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