I’m a stranger and I know more about you than you want me to.
Do you remember when the NSA scandal broke? Were you up in arms over The Government spying on you?
As we become more cognizant of being spied on, whether it be the NSA, red light cameras, targeted internet marketing or lurkers on our social media accounts, it sparks a certain uneasiness. What do they know about me? Why would they want to know it? Does the government care about my dirty texts and emails? What about that grocery list I just emailed myself?
I don’t know what is on your grocery list, but I do know what day you went to the store, how much you spent and if you used a debit card or a check. I know when you used your bank account to pay your electric bill. Those flowers that you bought with your debit card last week? I know that. Did you spend $1,000 on dog grooming or bet the entirety of your savings account on your fantasy football team? I see that, too. I am intimately familiar with you and your bank accounts in ways that The Government would be proud of. Though I can’t tell you that I hope your dog looks marvelous, just know that I think it.
Are you familiar with the financial provisions within the Patriot Act? How about the Bank Secrecy Act or anti-money laundering initiatives? These give me license to spy on your financial accounts. I work in financial compliance for a retail bank and it is my job to sniff out and report suspicious activity; even if it means that I learn how much you spend on dog grooming.
My official title is BSA/AML Administrator, which is a fancy way of saying that my goal is to catch those who are up to no good. Instead of using evidence like a detective would — blood spatter patterns, hair samples and such, I use bank accounts as evidence. If I’d worked for Chase at the time, I would have been responsible for bringing down Bernie Madoff. That would be the dream.
To effectively do my job, I have to familiarize myself with your financial habits. Did you traditionally keep a low account balance yet now bring in $20,000 in cash bimonthly? Red flag. Do you wire monies into your account only to wire it out the next day? Suspicious. Are your deposits and withdrawals aligned with your job and what we believe to be your financial status?
My position demands that I ask a lot of questions, which in turn means your friendly branch representative may ask you a lot of questions. You think that teller is just friendly? Chances are they are asking on my behalf. By gleaning information from the tellers and other branch staff, I’ll know if you want to buy a boat, remodel your kitchen or if you randomly found a sack of cash under a tree and decided to deposit it. (Just a word of advice, leave the sack of cash under the tree. We’d have to report you.)
Sometimes things that look suspicious are not. In one instance, a customer was working off the books at a night club but she would repeatedly joke that her cash flow was from prostitution. Once the branch reported this to the Compliance Department, we launched an investigation. Since the dealings were in cash and we only had the client’s “confession” to go on, we had to file a Suspicious Activity Report (SAR). The incident was investigated and yielded nothing. This woman’s name and the accusation are now part of the archives of financial crime. You can’t look it up online and you won’t find it unless you have access to the database. But behind the scenes, this woman’s name is now blemished and she will never know about it. A bank, by law, cannot inform a customer that they are filing a SAR on them.
It has also come to pass that our investigations fail. In my time as a financial spy, there has been activity that looked benign and the bank later got served with a subpoena from the District Attorney (DA). There is a lot of tax evasion out there and lots of levies out there. I know when you don’t pay your taxes and I know if you owe someone a sum of money and haven’t paid.
We can tell the client about financial levies, as we have to inform them that we are confiscating funds. Information subpoenas, we cannot tell the client about. Compiling these sometimes means printing out all of the activity an account has ever had. Wrote a check in 2007 to pay off your kid’s orthodontics? I see it. I print it. I send it to the DA. Put something into your account that you weren’t supposed to? A check made out to someone that wasn’t on the account, perhaps? I may have missed it the first time, but now I know.
In light of a recent Edward Snowden tell-all interview on MSNBC, even I have to wonder: Is spying OK and to what extent? How do you determine what activity is suspicious without looking through a few benign accounts first? I struggle with the latter question. Should I know these things? Does it bother you?