You conduct periodic analytical review of all transaction activity at Advanced Compliance Technology, Inc.. This review is separate from the daily review performed by teller supervisors.
\nYour monitoring program uses six alert parameters. Flag single cash transactions between $8,000 and $9,999 as sub-CTR alerts. Flag same-day transactions from one customer that aggregate to $10,000 or more as possible structuring. Flag customers who cash more than five checks within any 30-day period. Flag multiple checks from the same corporate account cashed within one week. Flag any transaction of $5,000 or more from a first-visit customer. Flag customers with addresses outside Advanced Compliance Technology, Inc.'s primary service area.
\nAlso monitor for six check cashing-specific patterns. Flag sequentially numbered payroll checks presented by unrelated individuals. Flag business checks with amounts inconsistent with known payroll cycles or headcount. Flag government benefit checks presented by third parties claiming power of attorney. Flag corporate checks without prior workers' compensation verification. Flag customers who previously failed CIP or were declined and are presenting again. Flag multiple customers presenting checks from the same employer without a plausible group payroll explanation.
\nWhen a supervisor escalates an alert, investigate using transaction history, prior alert records, CIP documentation, and open-source inquiry as needed.
\nAfter investigation, assign one of three dispositions: Cleared (no suspicious activity identified), SAR filed (suspicious activity confirmed), or Continued monitoring (alert is inconclusive — flag for 30-day follow-up). You must document every disposition. An undocumented disposition leaves no record that the alert was resolved.
\nWhen the disposition is SAR filed, initiate the SAR filing process. Attach the monitoring alert record to the SAR case file.
\nReview all monitoring thresholds annually. Also review after any significant change in transaction volume, customer mix, or regulatory guidance. Document each review in the threshold review log. Record the prior threshold, the revised threshold, the data reviewed (volume, alert rate, false positive rate), and the rationale for each adjustment.
\nMake ad hoc threshold adjustments outside the annual cycle in two situations: when the false positive rate exceeds 40% over any 90-day window, or when the confirmed-suspicious capture rate falls below 80% over any 90-day window.
\nMaintain four monitoring records. The alert log records all flagged transactions with the triggering parameter, date, disposition, and reviewer identity. The investigation file holds supporting documents for each escalated alert: transaction records, CIP copies, and your investigation notes. The SAR referral log cross-references monitoring alerts with SAR case numbers. The threshold review log records all threshold adjustments with supporting analysis.
\nRetain all monitoring records for five years from the date of creation. Records not retained for the full five-year period cannot be produced during an examination.
", "narration_text": "You conduct periodic analytical review of all transaction activity at Advanced Compliance Technology, Inc.. This review is separate from the daily review performed by teller supervisors.\r\n\r\nYour monitoring program uses six alert parameters. Flag single cash transactions between $8,000 and $9,999 as sub-CTR alerts. Flag same-day transactions from one customer that aggregate to $10,000 or more as possible structuring. Flag customers who cash more than five checks within any 30-day period. Flag multiple checks from the same corporate account cashed within one week. Flag any transaction of $5,000 or more from a first-visit customer. Flag customers with addresses outside Advanced Compliance Technology, Inc.'s primary service area.\r\n\r\nAlso monitor for six check cashing-specific patterns. Flag sequentially numbered payroll checks presented by unrelated individuals. Flag business checks with amounts inconsistent with known payroll cycles or headcount. Flag government benefit checks presented by third parties claiming power of attorney. Flag corporate checks without prior workers' compensation verification. Flag customers who previously failed CIP or were declined and are presenting again. Flag multiple customers presenting checks from the same employer without a plausible group payroll explanation.\r\n\r\nWhen a supervisor escalates an alert, investigate using transaction history, prior alert records, CIP documentation, and open-source inquiry as needed.\r\n\r\nAfter investigation, assign one of three dispositions: Cleared (no suspicious activity identified), SAR filed (suspicious activity confirmed), or Continued monitoring (alert is inconclusive — flag for 30-day follow-up). You must document every disposition. An undocumented disposition leaves no record that the alert was resolved.\r\n\r\nWhen the disposition is SAR filed, initiate the SAR filing process. Attach the monitoring alert record to the SAR case file.\r\n\r\nReview all monitoring thresholds annually. Also review after any significant change in transaction volume, customer mix, or regulatory guidance. Document each review in the threshold review log. Record the prior threshold, the revised threshold, the data reviewed (volume, alert rate, false positive rate), and the rationale for each adjustment.\r\n\r\nMake ad hoc threshold adjustments outside the annual cycle in two situations: when the false positive rate exceeds 40% over any 90-day window, or when the confirmed-suspicious capture rate falls below 80% over any 90-day window.\r\n\r\nMaintain four monitoring records. The alert log records all flagged transactions with the triggering parameter, date, disposition, and reviewer identity. The investigation file holds supporting documents for each escalated alert: transaction records, CIP copies, and your investigation notes. The SAR referral log cross-references monitoring alerts with SAR case numbers. The threshold review log records all threshold adjustments with supporting analysis.\r\n\r\nRetain all monitoring records for five years from the date of creation. Records not retained for the full five-year period cannot be produced during an examination." }