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!
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.
Published
2020/05/13
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