Case Study Summary

As a proactive measure, the Bank devoted resources to performing a self analysis privileged/compliance review  for Large Cash Transaction  reporting (CTR). The project included end-to-end process and system mapping, through to FinCEN reporting. A full cash reconciliation audit program was developed for ongoing annual validation.

The Client

Top 5 US Bank with a leading role in domestic and international business.

THE CHALLENGE

The Bank needed an independent organization to validate that all of their systems and processes across all lines of business throughout their organization were properly capturing cash information for CTR reporting to FinCEN. In addition, they needed to develop ongoing test programs to ensure subsequent modifications or enhancements did not alter the consistent flow and/or reduce reporting below 100%.

THE SOLUTION

DIG completed an end-to-end analysis and review of the Bank's systems and processes for ATMs, Branches, and Cash Vaults - both internal and external, and CTR operations. Working with the Bank, DIG prepared over 20 system and process mapping to document the flow and performed a gap/risk analysis of each and ever step in the process. The project included code level reviews of over 20 applications. During this review, DIG also performed a peer benchmark analysis to confirm and validate the Bank's methodology.  DIG developed and executed test routines to ensure accuracy of final reporting to FinCEN.·    

THE RESULTS

We recommended policy and process changes that would ensure accuracy of reporting. A number of gaps and risks were identified and the Bank quickly addressed these going forward. In addition the test results proved positive that systems and processes were correctly aggregating and reporting to FinCEN as required.