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-   -   Suspicious Activity Reports to the IRS when buying or depositing money orders. (https://www.flyertalk.com/forum/manufactured-spending/1438710-suspicious-activity-reports-irs-when-buying-depositing-money-orders.html)

Often1 Aug 25, 2013 5:51 pm


Originally Posted by FlightNurse (Post 21323970)
Have you talked to them about your mortgage? It's pretty simple, if they want your business open your accounts up, if not, there are other banks who want your business/mortgage.....

It is pretty simple, the AML compliance guy is deliberately in a different reporting chain so that he can't be influenced by how much business you do with the bank.

And, for what it's worth, it's doubtful that OP has a mortgage "with" the bank. It was likely sold to Fannie, Freddie or somebody else and the bank gets paid a bit to service the loan. Simply put, the bank could care less. Even if it could, it would not take on risk to earn a pittance servicing somebody else's mortgage.

AnalystGuy Aug 26, 2013 6:08 am


Originally Posted by Often1 (Post 21334303)
It is pretty simple, the AML compliance guy is deliberately in a different reporting chain so that he can't be influenced by how much business you do with the bank.

And, for what it's worth, it's doubtful that OP has a mortgage "with" the bank. It was likely sold to Fannie, Freddie or somebody else and the bank gets paid a bit to service the loan. Simply put, the bank could care less. Even if it could, it would not take on risk to earn a pittance servicing somebody else's mortgage.

This is true with respect to BSA/AML reporting but account closure decisions are not made in a vacuum and nearly always take the full relationship into account. But anyone who is driving up compliance costs (monitoring, analysis) and product costs (points, cash back) is not going to be given the benefit of the doubt or a second look unless they are somehow still profitable...and that is unlikely.
On a side note, I'm curious how many closures involved accounts that had direct deposit of payroll.

AlohaDaveKennedy Aug 26, 2013 7:43 am

Arghhhh! You are suggesting that the Cardinals answer to more than god and the pope. This is the sin of leading the blind (sheep) astray for "Cursed is anyone who leads the blind astray on the road." Deut 27:18

Have a nice day down there with Iblis and be sure to keep an eye on his new blog "Travelling to Hell in a Handbasket.":p


Originally Posted by AnalystGuy (Post 21336478)
This is true with respect to BSA/AML reporting but account closure decisions are not made in a vacuum and nearly always take the full relationship into account.


littlemookie Aug 26, 2013 6:40 pm

I had some info taken when my gf and I purchased 2.5k of MO's. It was a Kroger's (actually Smith's, which is part of Kroger's) but the strange part was that all he actually did was take my license, fill out a form and let me buy the MO's. I was surprised on two levels, one that he filled out the form for 2.5k, and for simply taking the info from my license. I'm guessing that the form is not filed with the IRS or treasury, but is kept in the store database. Smith's asks for a last name and phone number for any MO purchase (although doesn't actually ask for ID). It might be time for a new name. I'm thinking Carlos Danger might be a good name to use next time.

AnalystGuy Aug 27, 2013 7:02 am


Originally Posted by littlemookie (Post 21340840)
I had some info taken when my gf and I purchased 2.5k of MO's. It was a Kroger's (actually Smith's, which is part of Kroger's) but the strange part was that all he actually did was take my license, fill out a form and let me buy the MO's. I was surprised on two levels, one that he filled out the form for 2.5k, and for simply taking the info from my license. I'm guessing that the form is not filed with the IRS or treasury, but is kept in the store database. Smith's asks for a last name and phone number for any MO purchase (although doesn't actually ask for ID). It might be time for a new name. I'm thinking Carlos Danger might be a good name to use next time.

Danger, Carlos Danger
:D

Internal record keeping as part of their AML program.

Stubtify Aug 27, 2013 7:16 pm

Just wanted to inject a real story into this thread. There are very real, very bad people using the same techniques we think are harmless.

http://www.npr.org/templates/story/s...ryId=216250673

Las Vegas Sands To Pay $47.4M To Settle Fed Probe

LOS ANGELES (AP) — Casino operator Las Vegas Sands Corp. has agreed to pay $47.4 million after failing to flag millions of dollars in money transfers made by a gambler linked to drug trafficking.

In return, the U.S. Attorney's Office in Los Angeles will not seek an indictment against the casino operator, prosecutors said Tuesday.

The deal, finalized late Monday, also brings the government's criminal investigation to a close, but requires Las Vegas Sands to boost its efforts to monitor suspicious financial transactions for the next two years...

PaulMSN Aug 27, 2013 8:03 pm


Originally Posted by Stubtify (Post 21347413)
Just wanted to inject a real story into this thread. There are very real, very bad people using the same techniques we think are harmless.

http://www.npr.org/templates/story/s...ryId=216250673

Las Vegas Sands To Pay $47.4M To Settle Fed Probe

LOS ANGELES (AP) — Casino operator Las Vegas Sands Corp. has agreed to pay $47.4 million after failing to flag millions of dollars in money transfers made by a gambler linked to drug trafficking.

In return, the U.S. Attorney's Office in Los Angeles will not seek an indictment against the casino operator, prosecutors said Tuesday.

The deal, finalized late Monday, also brings the government's criminal investigation to a close, but requires Las Vegas Sands to boost its efforts to monitor suspicious financial transactions for the next two years...

No relevance, and not the same techniques, unless some of you are blowing your GC balances in Vegas.

drdrew450 Aug 27, 2013 9:56 pm

Not sure how much this helps, but I started depositing my MOs from the drive through cause I think its less likely to get questions and I am not as recognizable. I go in sometimes too since its usually diff people that work the drive through compared to the counter.

PaulMSN Aug 27, 2013 10:21 pm


Originally Posted by drdrew450 (Post 21348059)
Not sure how much this helps, but I started depositing my MOs from the drive through cause I think its less likely to get questions and I am not as recognizable. I go in sometimes too since its usually diff people that work the drive through compared to the counter.

At my CU, they rarely even blink. They just process the MOs and give me a receipt. I've been depositing $2000 at a time and about 4x a week. That will slow down once I've deposited all the Chase GC funds for the month.

AnalystGuy Aug 28, 2013 6:02 am


Originally Posted by Stubtify (Post 21347413)
Just wanted to inject a real story into this thread. There are very real, very bad people using the same techniques we think are harmless.

http://www.npr.org/templates/story/s...ryId=216250673

Las Vegas Sands To Pay $47.4M To Settle Fed Probe

LOS ANGELES (AP) — Casino operator Las Vegas Sands Corp. has agreed to pay $47.4 million after failing to flag millions of dollars in money transfers made by a gambler linked to drug trafficking.

In return, the U.S. Attorney's Office in Los Angeles will not seek an indictment against the casino operator, prosecutors said Tuesday.

The deal, finalized late Monday, also brings the government's criminal investigation to a close, but requires Las Vegas Sands to boost its efforts to monitor suspicious financial transactions for the next two years...

This case was about a failure (willful blindness) to know-your-customer and the source of his funds. And not reporting what they did actually know.

You are correct in pointing out that some of the techniques people talk about are not harmless. Taking any action to avoid required reporting is illegal. This includes breaking a deposit into smaller amounts and spreading it over several days. Note that intent is required, however. If you deposit twice a week simply because you buy your cards and MO twice a week that isn't illegal. If it appears suspicious to the FI though, they are obligated to file.

AnalystGuy Aug 28, 2013 6:17 am


Originally Posted by PaulMSN (Post 21348156)
At my CU, they rarely even blink. They just process the MOs and give me a receipt. I've been depositing $2000 at a time and about 4x a week. That will slow down once I've deposited all the Chase GC funds for the month.

This actually brings up an interesting point. The BSA/AML stuff usually happens behind the scenes and with software support. It is built right into the core banking systems. The CU doesn't blink because they know their systems are capturing all of your activity, and you are not acting (I assume) in any type of suspicious manner. They know you and your sources of income(another assumption)...if you worked for minimum wage and had that volume they might worry more.

Front line folks are trained to watch out for certain things for BSA and for fraud protection. It's up to the back office people to determine whether to file or not. The anti fraud aspect is often ignored...this is nearly as important to most FIs as the regulatory aspect.

AlohaDaveKennedy Aug 28, 2013 7:11 am

Indeed, there is a fine line between some of our work and the work of the press and fold folk which is why at times we don't feel the love from the cardinals in the banking system.


Originally Posted by Stubtify (Post 21347413)
Just wanted to inject a real story into this thread. There are very real, very bad people using the same techniques we think are harmless.

http://www.npr.org/templates/story/s...ryId=216250673

Las Vegas Sands To Pay $47.4M To Settle Fed Probe

LOS ANGELES (AP) — Casino operator Las Vegas Sands Corp. has agreed to pay $47.4 million after failing to flag millions of dollars in money transfers made by a gambler linked to drug trafficking.

In return, the U.S. Attorney's Office in Los Angeles will not seek an indictment against the casino operator, prosecutors said Tuesday.

The deal, finalized late Monday, also brings the government's criminal investigation to a close, but requires Las Vegas Sands to boost its efforts to monitor suspicious financial transactions for the next two years...


AlohaDaveKennedy Aug 28, 2013 7:15 am

Being recognizable is not necessarily bad. The bank is supposed to know their customers. If you are transparent and your bank(s) really know you are not about illegal activity and money laundering you can do some fantastic things within the banking system.:cool:


Originally Posted by drdrew450 (Post 21348059)
Not sure how much this helps, but I started depositing my MOs from the drive through cause I think its less likely to get questions and I am not as recognizable. I go in sometimes too since its usually diff people that work the drive through compared to the counter.


AlohaDaveKennedy Aug 28, 2013 7:29 am

But as we know from the credit reporting industry, those AML systems can be (legally) gamed just as credit reports can be (legally) gamed.:cool:

Part of the fun of this business is reverse engineering internal controls put in place. Benford's Law is trumped by the Cardinal Rule - All Internal Controls Degrade over Time.


Originally Posted by AnalystGuy (Post 21349466)
This actually brings up an interesting point. The BSA/AML stuff usually happens behind the scenes and with software support. It is built right into the core banking systems. The CU doesn't blink because they know their systems are capturing all of your activity, and you are not acting (I assume) in any type of suspicious manner. They know you and your sources of income(another assumption)...if you worked for minimum wage and had that volume they might worry more.

Front line folks are trained to watch out for certain things for BSA and for fraud protection. It's up to the back office people to determine whether to file or not. The anti fraud aspect is often ignored...this is nearly as important to most FIs as the regulatory aspect.


myndreamland Aug 28, 2013 7:38 am


Originally Posted by AlohaDaveKennedy (Post 21349691)
Indeed, there is a fine line between some of our work and the work of the press and fold folk which is why at times we don't feel the love from the cardinals in the banking system.

Any hint about where that fine line might be?


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