CAMS · Question #411
What should be part of an institution's monitoring and STR filing process? Choose 3 answers
The correct answer is A. Review on a regular basis of all high-risk accounts and transactions B. Review of STR filing trends and typologies C. Periodic training on the identification of red flags. An effective STR monitoring and filing process must include high-risk account review, trend analysis, and red flag training, but individual STR filings do not require Board of Directors approval.
Question
What should be part of an institution's monitoring and STR filing process? Choose 3 answers
Options
- AReview on a regular basis of all high-risk accounts and transactions
- BReview of STR filing trends and typologies
- CPeriodic training on the identification of red flags
- DRequirement that the Board of Directors approves the filing of an STR
How the community answered
(36 responses)- A83% (30)
- D17% (6)
Why each option
An effective STR monitoring and filing process must include high-risk account review, trend analysis, and red flag training, but individual STR filings do not require Board of Directors approval.
Regular review of high-risk accounts and transactions is foundational to transaction monitoring, ensuring that suspicious activity is detected, escalated, and reported in a timely manner.
Reviewing STR filing trends and typologies allows the institution to refine its detection methods and adapt to evolving money laundering patterns and techniques.
Periodic red flag training ensures that front-line and compliance staff can identify and escalate suspicious activity, fulfilling their individual obligations under AML regulations.
Requiring Board approval for each individual STR filing is not a regulatory requirement and would be operationally impractical; STR decisions are properly delegated to the BSA officer or compliance team.
Concept tested: STR monitoring program components and governance
Source: https://bsaaml.ffiec.gov/manual/AssessingComplianceWithBSARegulatorRequirements/13
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