Internet-Based BSA Compliance and OFAC Monitoring of Transactions

Our proprietary CP System™ was developed by software engineers in conjunction with certified anti money laundering specialists and lawyers who paid careful attention to the compliance needs of financial services provides, the regulators that oversee them and the banks that facilitate their commercial transactions. 

The CP System™ is designed as a real-time or post-transaction analytical tool for financial service providers.  Typically used by our money transmitter, currency exchange and check casher clients, the CP System™ can also be adapted to monitor the transactions of any company.  Thus, our software permits companies of all sizes to achieve the highest level of anti-money laundering and regulatory compliance without requiring the investment typically associated with the development and maintenance of automated systems that often focus on the processing of transactions, but lack a robust compliance module.

Our review of transactions occurs in “real time” as they are batched and received by Compliance Plus servers.  Through a secure File Transfer Protocol (“Secure FTP”), subscribing clients download into the CP System™ one or several batches of transactions (remittances, currency exchanges, cashed checks, wire transfers, etc.) processed by the client.  Compliance Plus’ software then analyzes each transaction and emits automated reports when required detections occur.

Our software allows for front-end and back-end analysis of transactions required by financial institutions.  These analyses allow our clients to identify and report suspicious activity, as well as validating their internal procedures.  In particular, the CP System™ offers five monitoring solutions in one: Rules-Based Transaction Red-Flagging, 314(b) Comparative Analysis, OFAC and Black List Screening, Look-Back and Historical Evaluations and Back-Up and Reporting Tool.

CP System 5-in-1 Solution

Rules-Based Transaction Red Flagging

 314 (b) Comparative Analysis

OFAC and Black list Screening

Look-Back and Historical Evaluations

Back-Up and Reporting Tool

Rules-Based Transaction Red Flagging

 

Many automated compliance tools are designed with built-in rules that are not flexible to accommodate the regulatory or compliance program environment of the consumer.  Recognizing that compliance programs and regulatory obligations vary depending on the type of products and services offered, the geographic location of businesses, markets serviced and agreements with correspondent companies and business partners, the CP System™ is designed as an “open” tool that can be adjusted to create filters to monitor and detect specific activity as required by our clients.

The CP System™ filters enable subscribers to comply with applicable BSA or anti-money laundering requirements.  At the same time, the software counts on numerous automated alerts that track the risk associated with specific services and customers. 

314(b) Comparative Analysis

Compliance Plus and subscribers of its CP System™ are registered as an Association of Financial Institutions with the Financial Crimes Enforcement Network (FinCEN).  As such, subscribers of the CP System™ are free to engage in information-sharing pursuant to Section 314(b) of the U.S.A. PATRIOT Act.  FinCEN and other regulators encourage information sharing as a means of reducing the risk of illicit activity, such as structuring, which may occur amongst companies, particularly those in the same industry.

Compliance Plus facilitates information sharing without divulging sensitive information that often restricts companies from participating in such programs.  Compliance Plus performs all reviews by pooling and aggregating the databases of subscribers to the CP System™.  Detected transactions based on 314(b) comparative analysis are provided to each subscriber individually, protecting the privacy of each participating company and its customers.  Thus, although the reviews are conducted by combining various databases, the reports and their content are provided confidentially to each subscriber.  Where compliance issues are detected across multiple subscribers, only generic information is provided.

OFAC and Black List Screening

The CP System™ is “OFAC-ready”, capable of providing front-end and back-end comparison of client transactions to the Specially Designated Nationals (SDN) List hosted by the United States Department of Treasury.  In addition to maintaining the SDN List, the CP System™ can be augmented with other publically available lists, as well as the private lists of its subscribers, thereby creating denial of service databases that are particular to our individual clients.

Look-Back and Historical Evaluations

While the CP System™ is designed to render immediate or delayed analytical reports, it offers subscribers the ability to run analysis of transactions over a period of time.  Look-back and historical evaluations are critical to an effective compliance program.  The CP System™ stores data in formats that can be searched and re-produced to highlight transaction accumulations, customer profile deviations, point of service activity, structuring, smurfing or potential fraud. 

In addition to assisting companies with enhanced reviews of their transactions, the aggregate nature of our database allows for near accurate transaction averages across several industries and by country, state and zip codes.  This provides an additional tool to detect when client operations exceed or are abnormally below the average of immediate geographic competitors. 

Back-Up and Reporting Tool

Providing CP System™ subscribers with alerts and detections related to their processed transactions is only part of our service offering.  Depending on the reporting requirements of our clients, the CP System™ is equipped with specific template versions of regulatory reports (Suspicious Activity Reports (“SAR”), Cash Transaction Reports (CTRs), periodic regulator reports, internal compliance forms) that are automatically generated based on selected filters.  This greatly enhances the timeliness and accuracy of compliance reporting and reduces the risk of violations for inaccurate or incomplete reporting.

© 2016 by Compliance Plus Services, LLC. All rights reserved.

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