BSA Tools in FLEX Workshop

Video Library Video Course Library BSA Tools in FLEX Workshop


This training provides an overview of the tools available within FLEX to assist credit unions in implementing Bank Secrecy Act (BSA) monitoring. These tools are designed to work in conjunction with your credit union’s internal policies and procedures to meet BSA requirements.

1. Bad Addresses

The “Bad Address” flag is a critical tool for identifying and managing problematic contact information within the FLEX system.

1.1. Application of Bad Address Flag

The Bad Address flag can be applied to:

  • Addresses (physical)
  • Phone numbers
  • Email addresses

1.2. Impact of Bad Address Flag

Accounts flagged with a bad address, particularly on the address or phone number, will have the following implications:

  • Cards will not be issued or re-issued for these accounts.
  • Unverified addresses and/or phone numbers will display in red for 30 days.
  • The issue will appear as an error on the Card Issue Report until resolved, even after the 30-day period.

1.3. Managing Bad Addresses

  • Edit Address:
    • Navigate to the “Edit Address” section to manage address details.
    • This section includes fields for Line 1, Line 2, City/State/Zip, and Country.
    • The “Red Flag Verification” status (e.g., “Verified (Not Red)”, “Not Certified”) is displayed here.
    • “Bad Address Date” and “Changed Date” are also visible.
    • You can view “Other Members Also Using Address” and their associated usage (Account, Beneficiary, Loan Applicant).
  • Reports:
    • Reports can be generated for accounts flagged with a bad address to track and monitor them.
    • Available reports include:
      • Bad Address Account Listing
      • Transactions to Bad Address Accounts
      • Bad Address / Bad Tax Address Report
    • These reports can be found under Internal Audit / Reports in the FLEX Main Menu.
  • Bad Address Fee Posting:
    • A fee can be charged for accounts with a bad address.
    • Location: Internal Audit > Bad Address > Bad Address Fee Posting (MS3030CA) in the FLEX Main Menu.
    • Configuration Options:
      • Which Address
      • Fee Amount
      • GL Offset
      • Branch Accounting
      • Take Balance Below Minimum
      • Worksheet or Post (FLEX strongly recommends running a worksheet prior to posting fees).
  • Address Change Notices:
    • Notices can be configured to print based on several criteria.
    • Configuration Location: System Administration > General Configuration > Configuration > Features (Page 2) in the FLEX Main Menu.
    • Key Configuration Parameters:
      • Address Verification Days: Number of days an address will appear in red after a change/verification.
      • Prompt for Name & Address Change?: Determines if a prompt for updated related addresses appears when an address is changed.
      • Send Notice to Old/New/Both Address: Specifies if the notice is generated for the old, new, or both addresses.
      • Print Notice When Address Changes: Indicates if a notice should be generated upon an address change.
      • Print Unverified Addr Change Only?: Determines if notices are generated only for changed addresses flagged as unverified.

2. Check Kiting Processing

The Check Kiting feature allows credit unions to monitor account history for potential check kiting activities.

2.1. Functionality

  • Credit unions can create reports with various scenarios to monitor account history.
  • The system provides a list of accounts that meet the defined report criteria.
  • Flag Accounts: This function places a hold on funds for any account that meets the criteria and is listed on the screen.

2.2. Location

  • FLEX Main Menu: Internal Audit > Check Kiting.

2.3. Configuration

  • Refer to “Check Kiting Processing” in FLEX Academy for detailed configuration information.

3. FinCEN (Financial Crimes Enforcement Network)

The FinCEN module enables credit unions to compare their membership database against the FinCEN Suspicious Activity listing.

3.1. Process Overview

  • When notified by FinCEN, credit unions must log into the FinCEN website and download the current FinCEN Match File.
  • Refer to “FinCEN” in FLEX Academy for additional information.

3.2. Key Features

  • Point of Contact: Stores credit union contact information that appears on the FinCEN Match Report.
  • Search FINCEN Matches: Allows credit union staff to run an individual member against the FinCEN Match File.
  • Account Bypass for Match: Once a false positive member has been verified, they can be added to the bypass file to prevent future false matches.

3.3. Multiple Transactions for Same Day Configuration

  • This option notifies staff of other transactions that have occurred for a member (by social security number) during the day, particularly useful for credit unions with multiple branches or shared branching networks.
  • Configuration Location: System Administration > General Configuration > Configuration > Features (Page 2) in the FLEX Main Menu. Look for “Show Multiple Trans For Today In TE.”

4. New Member Identity Check

This is a purchasable module that integrates with New Account Processing or can be used as a stand-alone option.

4.1. Functionality

  • Runs identity checks as part of new account processing.
  • Features and products may vary based on the credit union’s contract with the vendor.

4.2. Supported Vendors

  • Deluxe Detect
  • ChexSystems

4.3. Additional Information

  • Refer to “ChexSystems” or “Deluxe Detect” in FLEX Academy for detailed information.

5. OFAC (Office of Foreign Assets Control)

FLEX provides various methods to compare a credit union’s entire membership or individual members against the Specially Designated Nationals (SDN) and/or Palestinian Legislative Council (PLC) files.

5.1. OFAC Name Match

  • Compares the entire credit union membership database, as well as check payees and accounts payable vendors, to the SDN/PLC lists.
  • A report is generated as part of this process.
  • Automation Options:
    • Partial Automation:
      • Credit union is responsible for downloading the SDN/PLC file from the Treasury website.
      • OFAC Name Match is automatically run on FLEX via a scripted process.
      • Credit union staff is responsible for reviewing the OFAC Name Match report for potential matches.
    • Full Automation:
      • SDN/PLC file is automatically downloaded from the Treasury website and placed on the credit union’s server.
      • OFAC Name Match is automatically run on FLEX via a scripted process.
      • Credit union staff is responsible for reviewing the OFAC Name Match report for potential matches.
      • Note: Fees may be associated with full automation.

5.2. Individual and Historical Searches

  • Search OFAC SDN/PLC: Runs an individual or business name against the SDN/PLC list.
  • OFAC History: A searchable historical list of OFAC searches conducted on the credit union’s FLEX System.

5.3. Account Bypass Maintenance

  • Once a false positive member or accounts payable vendor has been verified, they can be added to the bypass file.
  • Records in this file are typically not compared to the SDN/PLC list in subsequent searches.

5.4. New Account OFAC Search

  • Members, joint owners, authorized signers, and beneficiaries are automatically screened against the SDN/PLC list during the new account opening process in FLEX.
  • This process runs in the background and only alerts the employee if a possible OFAC match is found.

5.5. Teller/Cashier Operations

  • Checks: Checks issued through Transaction Entry will trigger a warning if the payee’s name matches a name on the SDN/PLC list.

5.6. OFAC Compliance Reports

Several other reports are available and should be reviewed for OFAC compliance:

  • ACH Entry Possible OFAC Match: Generated during ACH processing, comparing incoming ACH items against the SDN/PLC list.
  • OFAC Log (OFLOG) Report: An End-of-Day (EOD) / End-of-Month (EOM) report detailing ALL items screened against the SDN/PLC on a given day/month.

6. Photo ID

FLEX provides functionality for storing and managing photo IDs.

6.1. Policy Recommendation

  • FLEX recommends establishing a policy for updating expired driver’s licenses or IDs stored in FLEX Photo ID.

6.2. Expiration Date Management

  • The expiration date should be entered when the license or ID is scanned.
  • The word “Expired” will display on any Photo ID records that have passed their expiration date.

6.3. Additional Information

  • Refer to “Photo ID” in FLEX Academy for more details.

7. Red Flag Verification

Regulation requires credit unions to develop policies and procedures defining what constitutes a verified or unverified address for Red Flag purposes.

7.1. Monitored Elements

Red Flag is monitored on the following:

  • Addresses
  • Phone Numbers
  • Email Addresses

7.2. Impact of Unverified Addresses

Addresses that are unverified could be affected in any/all of the following ways:

  • Unverified addresses and/or phone numbers will display in red for 30 days.
  • Cards will not issue or re-issue.
  • The issue will show as an error on the Card Issue Report until the address issue is resolved (even after 30 days).

7.3. Reports

  • A report can be generated on-demand showing all accounts with a red flag.
  • Location: Internal Audit > Reports in the FLEX Main Menu.

8. Reports for Transaction/Member Account Tracking

FLEX offers several reports to assist with tracking transactions and member accounts for BSA compliance.

8.1. Key Reports

  • Cash Transaction Analysis by Tax ID: An EOD/EOM report detailing cash, checks out, and checks cashed, grouped by social security number.
  • Daily Checks Report: An EOD report of checks received, checks cashed, and cash back exceeding $4999.00.
  • ACH Entry Possible OFAC Match: (As mentioned in OFAC section) Generates during ACH processing, comparing incoming ACH items against SDN/PLC list.
  • OFAC Log (OFLOG) Report: (As mentioned in OFAC section) An EOD/EOM report of ALL items run against the SDN/PLC on a given day/month.

9. Risk Level

Credit unions can assign a credit union-defined “Risk Level” to accounts within Address Maintenance.

9.1. Assignment Methods

  • Risk levels can be entered manually.
  • They can also be configured to use a drop-down box selection option.

9.2. Configuration

  • Default risk levels can be configured in Generic List Configuration under System Administration in the FLEX Main Menu.
    • Path: System Administration > General Configuration > Configuration > Generic List Configuration.

9.3. Reporting on Risk Levels

  • The FLEX Marketing Module can be used to pull a report on accounts flagged with a specific risk level.
  • Location: Member Relations > Marketing in the FLEX Main Menu.
    • Path: Member Relations > Marketing > Marketing.
  • Within the Marketing module, you can query for accounts based on the “Risk Level” field, specifying “Low” or “High” values.
  • Refer to “Marketing” in FLEX Academy for additional information on creating marketing reports.