Adapting AML monitoring for Remote Deposit Capture In its October 2011 assessment, FinCEN reports that Remote Deposit Capture (RDC) Suspicious Activity Report (SAR) filings increased substantially as use of the product has grown and as regulatory enforcement actions targeting the product were announced. As the report emphasizes, use of RDC internationally generated many of the SARs, via money service businesses and casa de cambio accounts, to deposit not only personal checks but money orders and traveler’s checks. The trifecta of risk —
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