It’s not suspicious, he does it all the time

by: Cindy Williams

Once, when I was conducting BSA training for front-line staff regarding suspicious activity, I gave them an example of a retired gentleman at the credit union that several times a week made multiple cash deposits of several thousand dollars. I explained that this was unusual behavior that might require some additional due diligence, perhaps ultimately resulting in the filing of a Suspicious Activity Report.

The teller who typically handled this member’s transactions happened to be in the room and replied, “But, it’s not suspicious, he does it all the time!”

This is a very good example of the challenge we face in ensuring our employees understand the requirements of identifying suspicious activity, as well as the importance of separating that requirement from the business relationships they may have formed with members. Understandably, it can be difficult to consider transactions unusual or suspicious when they are conducted by a member who is well known to the credit union. But, employees should be encouraged to maintain a healthy level of skepticism at all times, even while developing good business relationships with members.

In addition, even when employees “get it” during BSA training, the requirement to be on the lookout for unusual activity requires ongoing reinforcement. This can be handled via occasional email reminders, articles in a newsletter, discussions at staff meetings, or any other way that gets the reminder message out on an ongoing basis.

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