We recently sat in on an Association of Certified Anti-Money Laundering Specialists (ACAMS) webinar that addressed many of the rising issues related to the COVID-19 pandemic. They expect banks to see more online banking/mobile banking usage, as well as uncharacteristic transactions for certain customers.
These changes in customer behavior will ultimately result in increased transaction alerts within your BSA monitoring systems. This might include spikes in online banking, mobile banking, person to person (P2P) transfers, wires, etc. You’ll likely want to take a risk-based approach to handling such increases and that approach could also depend on your Business Contingency Plan (BCP). For instance, where does your BCP allocate your compliance resources? Perhaps your BCP calls for more resources, but in the event of the COVID-19 pandemic, you have actually had to reduce resources/personnel. Any necessary adjustments to your BCP should be documented and if you don’t have a BCP, develop one!
Some areas where you may or should see a change include:
- Bars and restaurants are generally closed to the public. Even though they may be operating on a take-out only basis, their overall activity should be decreasing. Even as they start to reopen, activity should still generally be less. If they continue to have “normal”, pre-COVID-19 activity, you need to determine why.
- Measures to prevent the spread of the virus have disrupted not only legitimate businesses, but illicit ones also. Those using bars, restaurants, salons, clubs and other business “fronts” for laundering ill-gotten funds must now find different covers. For example, human traffickers can’t openly operate front businesses like massage parlors; money couriers/mules will now stand out because of the decrease in air and interstate travel, etc. Businesses will be created, or compromised, in order to support activities and hide income derived from COVID-19 fraud schemes.
- Customers who have never used certain products or services (e.g., mobile banking, wire, P2P, etc.) will likely start doing so. You will need to determine if it’s normal given the times or unusual.
- Withdrawals of cash will likely increase due to fear or uncertainty in the economy. People may feel safer keeping cash at home or on-hand. It may be best to come up with a standard way of handling these requests IF other suspicious activity, such as structuring, is not involved. That way, activity analysts can address the increased alerts efficiently.
You might consider developing an NAICS list or AML monitoring scenario of restricted businesses. Continued activity could indicate illicit income from businesses that should be shut down during the pandemic.
This increase in alerts means more information to wade through. This is also challenging because you may not be working with a full staff at this time. Modifying your alert scenarios and thresholds temporarily might help reduce the volume but you should have controls and documentation in place prior to doing so, if it’s not addressed in your BCP. Make sure you have a change control process in place.
Alert thresholds should not be changed on a whim and you’ll likely want some approval process (BSA Officer) in place to do so. For example, IT should not be changing any sanctions alerts due to increased activity going through the financial system to support certain countries. Pay close attention to changes in sanctions and sign up for sanction alerts and issuances.
Be careful too about turning certain alerts off entirely as things will likely get missed. A better approach might be to do a delayed review, for example, every 90 days instead of every 30 days or an abbreviated review vs. a full review.
Ultimately, you need to focus on your program as a whole. Make sure it’s working, be realistic about what you can and can’t do, etc. Communicate with your regulators, especially if you’re unsure of your ability to meet reporting timeframes, etc. Your focus should be on your adaptability, resiliency and sustainability, not “pleasing” your examiners.
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Deb joined Banker’s Compliance Consulting with twenty years of experience in the banking industry. Her past positions include teller, credit review analyst, assistant financial officer, BSA Officer, Compliance Officer, and Director of Compliance. She has worked for both a small community bank and a large billion-dollar bank.
Deb has Associate Degrees in Business Management and Accounting. She is a graduate of the American Bankers Association National Graduate School of Compliance Management, an honors graduate of Schools of Banking Compliance School, and a graduate of Schools of Banking Advanced School of Banking. Deb’s considerable knowledge and experience make her a valuable member of the Banker’s Compliance Consulting Team. Deb is a Certified Regulatory Compliance Manager (CRCM) and a Certified Anti Money-Laundering Specialist (CAMS).
Deb loves to spend her free time cycling, running, kayaking and weight lifting with her husband. Between them, they have three adult children and six grandchildren. Other interests include anything outdoors and anything she hasn’t done or seen yet!