BSA/AML/CFT Risk & Phone Transfers
When you think about all the potential risks out there that might set off your BSA/AML/CFT radar, phone transfers aren’t typically on the top of that list. However, we recently worked with a financial institution where a customer was receiving their payroll via telephone transfers. These phone transfers weren’t detected as suspicious by the institution’s automated monitoring system and really only came to light because the customer’s employer was also a bank customer. While there were a lot of moving parts with this particular scenario, it’s a good reminder that both your commercial and consumer teams play a key role in detecting suspicious activity.
Emily and Kevin discuss this in the video.
Published 2026/10/20
Kevin Edwards
Kevin brings years of experience and a unique perspective on regulatory matters to our clients. A self-proclaimed geek and accredited CRCM, Kevin is also a recovering attorney with experience as in-house counsel for a large regional bank and one of the leading national title insurance providers. For reasons unknown, Kevin decided to leave the safety and serenity of his desk job to seek fortune and glory as a wandering adventurer. Like a bank compliance version of Kwai Chang Caine, The Man with No Name or Don Quixote, he now travels the land seeking to help those in need and righting compliance wrongs, wherever he may find them. Kevin lives in Sioux Falls with his two children, who are surprisingly normal after having endured their father’s vivid imagination for their entire lives. He won’t admit to having any hobbies, because apparently “Regulations never sleep.” (While he does say this in his Batman voice, we’re pretty sure he’s joking.) From the looks of his Facebook page, he likes the outdoors and spending time with his large extended family (who seem like relatively normal people).