Acronyms
CRM
Compliance Risk Management
M&T Banks Chief BSA officer
Matt Haslinger
Bank where check was negotiated
BOFD
moving money quickly through an account, typically at least one debit and one credit must exist.
FTF - Flow Through of Funds
A ____________ review of the account noted debit activity commensurate with daily living expenses; including charges at Dollar Tree, Price Chopper, and Amazon in amounts up to $324. Credit activity consists of payroll deposits in amount up to $1,452.
cursory
OFAC
Office of
Foreign Asset
Control
M&T Bank's Chief Compliance Officer (CCO)
Greg Imm
comprehensive demographic and risk assessment for US entities
Lexis Nexis
MIPwC
Monetary Instrument Purchased with cash
According to the _______ _______ for Tammy Lee, she is rated as high risk as a result of a SAR filing with a risk score of 5. No other flags were noted.
KYC profile
UAR
Unusual Activity Referral
SAR Team Manager
Jen Morgano (Pici)
wires
PARC
cash transactions conducted just below the FinCEN Filing requirement
Structuring
CRR _____________ Flags
overrides
CTA
Customer Transaction Achieve
Head of the FIU
Dale Kasperzak
Signature cards, UBO forms, Debit card application, business documentation
What is FileNet
Growth in Wire, Growth in cash, change in payment history all belong to this Actimize trigger category
HBC (Historical Behavior Comparison)
after ______ SARs in 12 months OR _____ SARs total we are required to address the relation escalation and typically recommend an exit.
3 and 5
PARC
Payments Archive and Research Center
Head of the BSA Liaison Team
Brian Borowski
Account activity since the end of the last statement
T Screen
Large cash Report , Top cash report are combined to make up this Actimize trigger category.
ECT (Cash/Cash-Equivalent)
Section ________ of the ____________Act allows us to share information with certain other Financial Institutions for limited purposes of identifying and reporting activities that may involve terrorist financing or money laundering.
314(b) - USA PATRIOT Act