Per federal and state guidelines, MSBs are required to monitor their customers’ transactions for suspicious and illegal activity.
Over the past year and a half, the Federal and State governments have issued a huge amount of money to individuals and businesses in the form of Covid-19 stimulus packages. Criminals have been exploiting this situation by committing financial crimes at an unprecedented rate. See a few examples below.
“IRVINE, Calif. (KABC) — An Irvine man allegedly obtained about $5 million in federal coronavirus-relief loans for his fake businesses and then spent the funds on himself, including buying Ferrari, Bentley and Lamborghini sports cars, according to federal authorities.”
“BOSTON — The owner of a Massachusetts pizza parlor lied about the number of employees he had to fraudulently obtain more than $660,000 in federal coronavirus relief funds, then used some of the money to buy and stock an alpaca farm in Vermont, federal prosecutors said Tuesday.”
“According to the report by the Times, Abidemi Rufai, of Lekki, Nigeria, was charged Saturday in federal court with using the identities of more than 100 Washington residents to steal more than $350,000 in unemployment benefits from the Washington state Employment Security Department (ESD) during the COVID-19 pandemic last year.”
How can you improve your quality of monitoring?
Here are some tips on how to get better:
It all starts with making employee training a fundamental part of your business and your culture. Requiring your employees to pass a test is one thing but asking them to join you in putting those practices into play inside their roles each day brings a new level of awareness to their work.
Employees need to know what to look for when they are seeing suspicious behavior or activity. For example, what kind of typology are fraudsters using? What kind of schemes should employees be looking for?
Know who you are doing business with and how they conduct their business. For example, is a construction company cashing $3M of checks each month but they just got incorporated six months ago? That is a red flag.
Help your employees to think critically about each customer and transaction. Most fraudulent activities can be uncovered by using common sense. Do not over complicate it.
Use your check cashing software as a resource for monitoring. Most software has features that will give you alerts and allow you to sort the information several ways including insights into historical data on customers. This goes back to training. The more your employees know how to get the most from the software the less mistakes they will make.
Reporting should be a natural extension of your monitoring practices. If you are making your monitoring a high priority, good reporting will naturally flow from those activities.
It is very important to file CTRs on a timely basis, within 15 days.
If you are using your check cashing software fully, it will help with the practice of reporting. Especially with CTRs, when a suspicious activity is identified, your software will trigger a CTR. In addition, it will aggregate the data on a customer, pulling all their transactions together if they have made multiple transactions at different times of the day.
Investing in additional features like these and learning how to use them minimizes mistakes.
For example, if a customer comes in three separate times during a day and cashes a $5,000 check each time, will your employees know to aggregate all of those transactions? If not, this is where the software can minimize mistakes.
We understand that your team is most likely not trying to intentionally ignore possible suspicious activity. However, if they get busy and are rushed, without these extra measures in place to catch mistakes they are more likely to make a human error that could cost you.
Our Commitment to You
One of our highest priorities and commitments to you is to make sure our BSA staff is highly qualified and properly trained.
As we seek to be a resource for you, we hold ourselves to the highest standard as well. We are in the business of compliance, so we take employee training, monitoring, and reporting very seriously.
If you have questions for our team and would like to connect, you can reach us here.
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