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Wire Transfer Records / Logs -The BSA requires wire transfer records. Periodic review of this information can assist banks in identifying patterns of unusual activity. A periodic review of the wire records/logs in banks with low wire transfer activity is usually sufficient to identify unusual activity. For banks with greater wire activity, use of spreadsheets or vendor software, is an efficient way to review wire activity for unusual patterns. Most vendor software systems include standard suspicious activity filter reports. These reports typically focus on identifying certain higher risk geographies and larger dollar wire transactions (persons and corporations). Each bank should establish its own filtering criteria for both personal and corporate wire volumes based on their customer base. Non-customer wire transactions and Pay Upon Proper Identification (PUPID) transactions should always be reviewed for unusual activity.

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