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1.
Does the weekly scan of OFAC include Non-Members? Views: 411
Every Saturday, Operations will automatically run the OFAC scan on both members and non-members.
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2.
How do I determine if I have a valid OFAC match? Views: 408
To determine if you have a valid OFAC match, follow the ‘due diligence’ steps on the Department of Treasury website at http://www.treasury.gov/about/organizational-structure/offices/Pages/Office-of-Foreign-Assets-Control.aspx
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3.
What is Audit Link? Views: 398
The Audit Link service consists of three interrelated business activities. The first is an overall analysis of the credit unions needs, hot buttons, and recent audit or examination findings. This analysis is designed not only to tailor the program for the credit union but also to facilitate an overall general compliance tune-up. The second area of this initiative is the development of a daily, monthly, and quarterly roadmap of tasks to be completed. This is where the credit union would see the More...
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4.
How do I look up OFACs that have been overridden? Views: 386
Every OFAC scan that is overridden has a specific Tracker memo type that is generated when the override occurs. This memo type is OO (letters, not zeroes) and is configured to appear in the audit tracker. Use Tool #664 Print Member Trackers to generate a report containing the data you are looking for. Ensure that the tracker type is set to AT and the memo type is set to OO.
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5.
What types of transaction patterns can you create for Abnormal Activity Monitoring? Views: 353
The following types of transaction patterns can be created: Velocity : This evaluates if the member has an unusual amount of transactions that fall within the criteria configured. Idle : This evaluates if the member has an unusual flurry of activity (either based on # of transactions, transaction type, or transaction amount) following a period of inactivity. Out of the ordinary : This evaluates if the member has a percent or amount increase compared to a prior activity.
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6.
My member deposited a large check deposit. How do I release the funds across three hold release dates, according to the Reg CC guidelines? After the initial Reg CC release, I would like to release a set amount after a three-day hold, and the rest after an additional four days. What do I do to configure this in the system? Views: 333
Your credit union can opt to release funds differently for amounts above a certain dollar amount threshold (such as $5,000), on a single deposit. This affects how all deposit holds are placed, no matter how other channel-specific settings (teller, mail/direct, Remote Deposit Capture (RDC), and ATM) are configured. One place this will not be used is with National Shared Branch (COOP) transactions. For example, if a member deposits a $17,500 check, the system could be instructed to hold the first More...
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7.
For IAT OFAC scans, are addresses scanned as well? Views: 321
It is not currently a requirement to have the address line scanned for an IAT. CU*BASE does not currently scan it as it is in a free-form format rather than in a formalized pattern.
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8.
What does it mean on the first Abnormal Activity transaction pattern configuration screen when you elect to include only shared branch transaction, only RDC transactions, or only P2P transactions? Views: 308
When one of these options are selected, only those transaction types will appear in the results dashboard. You may select only one of these checkboxes (e.g., you may not select to include only shared branch transactions and only RDC transactions). When one of these options is selected, you cannot also select specific origin codes to monitor. Shared Branch Transactions : The pattern will monitor only shared branch transactions. RDC Transactions : The pattern will monitor only RDC transactions. P2 More...
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9.
What tools can I use to get started with Abnormal Activity Monitoring? Views: 305
To configure abnormal activity monitoring patterns or groups via Tool #101 Abnormal Activity Monitoring Config , you will first need to determine your credit union's thresholds for normal and abnormal activity. You may start from scratch or base patterns on previous cases of fraud. Basing Patterns on Past Fraud You can reverse engineer patterns based on fraud you’ve experienced in the past. Configure the pattern to monitor the same type of transaction and base the threshold numbers aro More...
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10.
For out of the ordinary Abnormal Activity Monitoring transaction patterns, should I include both an amount and percent? Views: 221
It is not recommended that you include both an amount and a percent in out-of-the-ordinary patterns since they are AND qualifiers. It would be rare for a member to match both criteria at the same time.
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11.
Who provided the thirty Abnormal Activity Monitoring transaction patterns I receive by default? Views: 216
These patterns are provided by AudlitLink. They recommend you follow proper governance change process when making changes to these patterns.
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12.
How can you “practice” to see if a transaction pattern will return any results? Views: 202
The configuration ( Tool #101: Abnormal Activity Monitoring Config ) allows you to run a test of a transaction pattern that you have configured. In this manner, you can see the results without running all the patterns in the monitoring side ( Tool #537: Monitor Abnormal Transaction Activity ). In this test mode, you have a limited number of buttons, but you can print the results. AuditLink is currently offering monthly webinars about the Abnormal Activity Tool. Watch for future communications.
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13.
We would like clarification on why aliases found on the OFAC Sanctions list do not result in True-Positives when searched using Tool 778 (Scan a Single Name Through OFAC). Reviewing the "Using the CU*BASE Data Match System for OFAC Compliance" resource, it states that AKA names are searched. Evidently there are two AKA lists, one embedded in the SDN Comments Section and a separately published list. Views: 198
This is what FinCEN has stated in the past about weak aliases: Am I required to screen for weak aliases (AKAs)? OFAC’s regulations do not explicitly require any specific screening regime. Financial institutions and others must make screening choices based on their circumstances and compliance approach. As a general matter, though, OFAC does not expect that persons will screen for weak AKAs, but expects that such AKAs may be used to help determine whether a 'hit' arising fro More...
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14.
For Abnormal Activity Monitoring by transaction pattern, what recommendation are there when I evaluate members for individual and organization accounts? Views: 193
It is recommended that you make the same rules for both individual and organizational accounts when you make velocity patterns, out of the ordinary patterns, and idle patterns.
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15.
What is the amount of the Reg CC hold release? Views: 180
As of July 1 st , 2025, the Reg CC amounts adjusted for inflation. The new release amount is $275.00. To remain in compliance, CU*Answers updated automated processes; however, there are items to consider that may need to be updated by the credit union. The list below includes items to consider but may not be all encompassing. Funds Availability Policy Websites Member Forms Internal Procedures/Policies Member Notices ( Tool #258 ) Misc. Member Account Forms ( Tool #261 ) CU*Publisher Custom URLs/ More...
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16.
We attended a web conference on the many compliance configurations on the system. How can I view a recording of this training? Views: 180
You will find the Using CU*BASE Tools for Bank Secrecy Act Compliance on the On Demand website. See the link below.
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17.
What general recommendation is there when making transaction patterns for Abnormal Activity Monitoring? Views: 178
It is recommended that you monitor a smaller set of transactions when creating transaction patterns.
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18.
For out-of-the-ordinary patterns for Abnormal Activity Monitoring, why is there a qualifier that looks for accounts above a total dollar amount of transactions for the period selected? Views: 171
It is recommended that you use this qualifier to limit the number of false positives you receive in your results.
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19.
What general recommendations are there for creating ACH stop-no-go abnormal activity monitoring patterns? Views: 158
Always configure your stop-no-go patterns using thresholds that signify abnormal activity for your membership base. Research typical member activity within different membership groups to base your thresholds on. When configuring a velocity threshold for a stop-no-go pattern, AuditLink recommends configuring the threshold for a high number of transactions of a lower amount. Be sure your pattern criteria are reasonable prior to activating the monitoring pattern. When you select to activate your AC More...
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20.
I have a new BSA Officer. Where is a good place to start with them? Views: 147
The team at AuditLink performs daily monitoring activities on behalf of credit unions to assist in the fulfillment of Bank Secrecy Act (BSA) compliance requirements. The same procedure guide their team uses to do this work is now available to credit unions. Click the link below to order the free Daily and Weekly Procedures guide from AuditLink.
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21.
We are interested in using the Abnormal Activity Monitoring Tools. Does AuditLink have any resources on this topic? Views: 141
Audit Link has many ways to learn about Abnormal Activity Monitoring Tools. Follow the links below.
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22.
Can you direct me to the link of where I get an updated due diligence package for our vendor management system? Views: 139
You can find Due Diligence materials here: https://www.cuanswers.com/about/due-diligence-materials/
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23.
What information does Audit Link’s Negative Situation Monitoring product provide? Views: 125
Performed on a daily basis, Audit Link uses the CU*BASE Dashboard for Negative Balance Analysis to retrieve negative balance data. A daily report summary is provided to your team illustrating negative balance accounts separated as 15-day buckets to assist in quickly identifying possible fraudulent activity and areas that may require immediate action. Also included with the daily report summary are graphical representations and delinquency ratios to assist in identifying key trends affecting your More...
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24.
What do federally chartered credit unions need to enter for the transaction description for the “Non-Return fee” (on the NSF and Overdraft Protection detail screen) in order to remain in compliance with the NCUA? Views: 112
If you are a federally chartered credit union, enter the words “Overdraft fee” in this field to remain in compliance. This is because that description is what is used on the fee summary disclosure on the statement, and federally-chartered credit unions must use this specific terminology. • NOTE: If you are adjusting your description, you may also want to include a statement message to alert members to the change.
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25.
We had a CTR form pop in error. The teller miskeyed a cash transaction that exceeded $10,000 but they noticed the error and fixed it. What do I do with the CTR Form? It isn't needed. Views: 106
When the CTR form pops up, even though the cash total is due to an error, the teller should fill out the form until they reach the screen with the ‘Skip Form’ option. This will allow them to stop the CTR process and a tracker screen will appear where they will need to document a reason for skipping the CTR form.
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