Union Bank and Trust Company
Wire Transfer Risk Assessment
Overview
Many consumers and businesses conduct electronic bank-to-bank financial transactions through wire transfers. A wire transfer is a process of moving money from one account to another, across financial institutions. While this activity is convenient, it does not come without risk.
Union Bank and Trust (the Bank) acts as both an originator and receiver of domestic and international wires. The Bank will be using the Federal Reserve Bank’s FedLine Direct program integrated with Jack Henry’s Silverlake DirectLine Wires Platform to process domestic wire transfers. Domestic wires will be processed through the Jack Henry & Associates (JHA) Silverlake system using the DirectLine …show more content…
Risk: Undetected, unusual and suspicious activity
Mitigation Strategies:
A. All wires are reviewed monthly, and placed on a spreadsheet that is reviewed quarterly, by the BSA Committee for any suspicious activity.
B. Consumer international wires are monitored by the Compliance Manager to assure that the Bank remains exempt from the Remittance Transfer Rule.
C. Periodic internal/external audits are performed by third party firms.
D. The Bank’s Customer Identification Program (CIP) and Customer Due Diligence (CDD) Program enables the Bank to effectively monitor, identify, and report unusual and suspicious funds transfer activities.
4. HIGH RISK ACTIVITIES
Financial institutions that engage in Wire Transfers with high-risk originators or receivers face increased exposure. High-risk originators and receivers include companies deemed high-risk by the completion of a risk assessment at account opening. This could be because of the type of business or NAICS code, or the type of activities they are associated …show more content…
Management provides adequate controls including segregation of duties, dual control, and accounting.
B. Management has implemented sound operating processes, information systems, internal control, and audit coverage.
Risk: Security Controls
Mitigation Strategies:
A. Only authorized staff, have access to wire transfer software (PCBB) with a current certificate and password.
B. With PCBB and Silverlake, dual control is in place for initiating and authorizing wires.
C. Board approved initiation and authorization limits are in place based on job function.
D. User access review performed at least annually to ensure all users have appropriate access and limits.
7. INFORMATION TECHNOLOGY RISK
Information technology enables banking organizations to carry out their wire activities more efficiently and effectively, however Information Technology can also be a source of risk for the financial institution and the customer.
Risk: Disaster takes place that affects the access to PCBB or Silverlake
Mitigation Strategies:
A. Board approved Business Continuity Plan is in place
B. Appropriate processes and controls exist to manage and protect
Wire Transfer Risk Assessment
Overview
Many consumers and businesses conduct electronic bank-to-bank financial transactions through wire transfers. A wire transfer is a process of moving money from one account to another, across financial institutions. While this activity is convenient, it does not come without risk.
Union Bank and Trust (the Bank) acts as both an originator and receiver of domestic and international wires. The Bank will be using the Federal Reserve Bank’s FedLine Direct program integrated with Jack Henry’s Silverlake DirectLine Wires Platform to process domestic wire transfers. Domestic wires will be processed through the Jack Henry & Associates (JHA) Silverlake system using the DirectLine …show more content…
Risk: Undetected, unusual and suspicious activity
Mitigation Strategies:
A. All wires are reviewed monthly, and placed on a spreadsheet that is reviewed quarterly, by the BSA Committee for any suspicious activity.
B. Consumer international wires are monitored by the Compliance Manager to assure that the Bank remains exempt from the Remittance Transfer Rule.
C. Periodic internal/external audits are performed by third party firms.
D. The Bank’s Customer Identification Program (CIP) and Customer Due Diligence (CDD) Program enables the Bank to effectively monitor, identify, and report unusual and suspicious funds transfer activities.
4. HIGH RISK ACTIVITIES
Financial institutions that engage in Wire Transfers with high-risk originators or receivers face increased exposure. High-risk originators and receivers include companies deemed high-risk by the completion of a risk assessment at account opening. This could be because of the type of business or NAICS code, or the type of activities they are associated …show more content…
Management provides adequate controls including segregation of duties, dual control, and accounting.
B. Management has implemented sound operating processes, information systems, internal control, and audit coverage.
Risk: Security Controls
Mitigation Strategies:
A. Only authorized staff, have access to wire transfer software (PCBB) with a current certificate and password.
B. With PCBB and Silverlake, dual control is in place for initiating and authorizing wires.
C. Board approved initiation and authorization limits are in place based on job function.
D. User access review performed at least annually to ensure all users have appropriate access and limits.
7. INFORMATION TECHNOLOGY RISK
Information technology enables banking organizations to carry out their wire activities more efficiently and effectively, however Information Technology can also be a source of risk for the financial institution and the customer.
Risk: Disaster takes place that affects the access to PCBB or Silverlake
Mitigation Strategies:
A. Board approved Business Continuity Plan is in place
B. Appropriate processes and controls exist to manage and protect