By Kyle Woodmansee

I don’t know about you, but I can’t believe it is 2012 already. FinCEN is starting the new year with some guidance on identifying “account takeover” suspicious activity. FinCEN defines “account takeover” as the act of using computer intrusion to target a member holding an account at a credit union to remove, steal, procure or otherwise affect the member’s funds.

A common misconception is that a credit union’s IT department is the only line of defense, which is not the case. FinCEN provides the following “red flags” for this type of activity; unusual ATM activity, clustered ACH transactions in different geographical areas, sudden wire transfers, and changes to a member’s account or profile.

OFAC has released a new SDN search tool on its website located here to help your credit union determine who is naughty or nice this holiday season. As always, OFAC provides the following:

We all know that you need to provide your MIP (Member Identification Program) notice to potential members prior to them opening up a new account, right?  Some of you may provide the notice prior to taking the application, others may provide the notice by prominently posting it on the credit union wall, or you may just elect to include the notice in your member packets. 

If you are wondering what the MIP notice says, here it is:

FinCEN released its second quarter Mortgage Fraud SAR Report. The report indicates that mortgage SARs continue to be on the rise and showed an increase from the first quarter report. I found this chart to be interesting:

It looks like FinCEN is preparing to save some trees. FinCEN has proposed a rule to make the electronic filing of reports required under the Bank Secrecy Act mandatory. FinCEN  stated that the move will improve efficiency, reduce costs, and enhance the ability of its investigators, analysts, and examiners to review the  reports. The proposed rule is open for comments and if implemented, would require e-filing as of June 30, 2012.

I was out in Colorado conducting a BSA training session with Andrea last week and I have to say that I never get tired of looking at the mountains.  Maybe that is because Iowa is not known for its changes in elevation, but I think it is more because I am all about the beauties of Mother Nature.

One discussion that we had while in Colorado was the reasoning behind the discrepancy in CTR filing requirements. It seems strange that a credit union must list  all joint account holders on a CTR for deposits of currency greater than $10,000 but only list the individual/s conducting the transaction for a withdrawal of currency greater than $10,000.