Royal Bank of Canada (RBC) has a private banking unit based in Miami that serves about 3,000 high net worth non-resident aliens. These customers initiate approximately 12,000 transactions per day. Making sure that these transactions comply with anti-money laundering regulations, including the USA PATRIOT Act, isn't something that can be done without software.
"There's no way you can monitor this manually," said Lino Lineras, senior operations manager USA for RBC. "Even if you had 100 customers, with a nice size volume you couldn't monitor it by hand and have an Excel spreadsheet to keep track."
"The more manual operations, the more risk you have," said Lineras. But when RBC installed Miami-based AmericaSoftware's "ASSIST//ck," it removed much of that risk.
Upon installing the software a year and a half ago, the first step was to develop profiles of its existing customers. "ASSIST will develop a profile for you, if you don't have the time to do it, based on maybe two years of funds movement of the customer," said Lineras. "Once you have everything loaded, you can start modifying those profiles to fit into the actual customer movement."
Existing policies made the private bank ready to comply with the USA PATRIOT Act. "We already had our operations and our due diligence standards geared before that," said Lineras. "We already ask for more than one source of ID for a customer. We visit customers on a frequent basis. We're on top of them any time there's a change in the nature of the business that they're doing."
However, the Federal Reserve and the state banking agencies, which conduct audits of state-chartered banks on alternate years, are conducting more scrupulous examinations in the current environment. RBC uses ASSIST to generate reports that evaluate customers' funds movements according to factors including country of origin, occupation and net worth. "Every time that we are audited by the Fed, they look at the reports from ASSIST," said Lineras. "Every time that we are audited by the state, they also go by that."