Below are seven tips for BSA best practices for front-line staff that will foster, not hinder, customer/member relationships while providing ongoing due diligence and supporting CDD compliance requirements.
Advise tellers on thresholds.
Advise tellers of the bank’s quantitative threshold on cash activity that should prompt a conversation with the customer or member. Tellers may feel a discussion is warranted even with transactions below this threshold or may not be required once they get to know the person and their business. But setting guidelines for when to ask questions reminds the front-line employees to pause and evaluate each unique situation.
Encourage conversation with the customer or member. Many customers coming into the branch are elderly and love to come in specifically to chat with employees. You will want to take the opportunity to get to know them. They are a prime target for many scams, and these conversations could save them thousands of dollars.
Provide sample questions to start a conversation. Tellers should avoid statements such as, "I'm required to ask what this money is for/from." For many people, finances are a deeply personal business, and inquiries such as these can put someone on the defensive. Instead, phrase the question in a way that's conversational and non-threatening. A straightforward approach is to make a wild guess as to what the funds are for – the crazier, the better. People will often laugh at this guess and correct it out of habit, voluntarily offering you the necessary information. For example:
- Wow, this is the going price of a unicorn. You aren't buying a unicorn, are you?
- The lottery jackpot is up to 3 million – did you win?
- It's vacation season. Any fun travel plans coming up?