Doris Birmingham: Evolving with BSA

Doris Birmingham

Doris Birmingham is the administrative officer, senior Bank Secrecy Act (BSA) analyst at American National Bank of Texas (ANBTX). Previously, Birmingham was a senior auditor with direct reports and specialized in retail/consumer banking and compliance audits, including BSA, the Sarbanes Oxley Act (SOX), the Privacy Act and the USA PATRIOT Act. She has a proven ability to communicate and build strong relationships throughout the banking network, including upper management and staff. In addition, Birmingham has managed audit teams performing procedural and compliance audits, including budgeting for travel, reviewing completed files, compiling audit findings and preparing draft reports for submission to the audit director.

ACAMS Today (AT): Tell us about what your job entails and when you started in the anti-financial crime (AFC) industry.

Doris Birmingham (DB): I began my career as an internal auditor at a financial institution (FI) focusing on retail, and also worked within their compliance department. This included BSA compliance. In the mid- ‘70s, my BSA career officially began and I also did some internal auditing, and then in 2009 (due to a displacement caused by the FI being sold), I moved solely into BSA compliance.

I wear numerous hats. I have cases where I work through our anti-money laundering (AML)/BSA monitoring system and I generally concentrate on high-risk customers. I also delve into fraud cases as we do a final review of those since we are also the ones who file the suspicious activity reports (SARs). In addition, I do trainings for new employees in our department as well as continued trainings with peers in the department who want to expand their experience because we have different levels of cases, like those that are high-risk or deal with nongovernmental organizations. Besides these tasks, I also enjoy doing the more specialized tasks that my boss assigns me.

AT: How has the industry evolved since you started your career?

DB: Technology, of course, would be number one on my list. Technology is being used to get things filed. It’s so structured and you do it online now. I don’t know many people that file manually anymore; however, filing online speeds everything up.

Since I began my work career 49 years ago, there has been a lot of movement and changes that began in the ‘90s under the Financial Crimes Enforcement Network (FinCEN) guidance and enforcement supporting federal, state and international law. Having been there from the beginning and working through all those changes and then trying to understand the activity that’s going on, it’s just one huge area of learning for me. It’s interesting because you must stay abreast of all the new fraud. Changes mean we have various institutions sending emails all the time to keep the industry updated, and so we need to make time to read them. Some of those are FinCEN’s guidance. We have a file where we put all those updates. If someone is doing a review and investigation, they can look to see if there is any guidance from FinCEN, get some verbiage from there and file their narrative if they need to.

AT: What has helped you grow with the industry?

DB: Continuous training has helped me grow the most. We’re required to do so much training annually, which is a good thing, and we’re allowed to go to a couple of conferences a year. Generally, I just go to one conference because of my heavy workload, but I do try to keep up with guidance.

On-the-job training is second on my list as far as career tips that helped me grow. The BSA team has regular meetings where we discuss items such as a SAR we recently filed that the other analysts would not necessarily know about. We also make all our cases available so that everyone can review and use them as samples if needed. That’s how we stay connected and continue to grow despite all the different things we do.

AT: Please share some takeaways you have learned to stay agile in the AFC sector.

DB: One of the things that I do is stay abreast of the ongoing changes, additions and requirements by staying connected with agencies and their updates on current issues.

Takeaways from conferences also help me stay agile. Those from my department who attend conferences try to pick different ones to attend throughout the year. After attending, we share one or two things we learned during our training sessions and share those with our peers.

Communicating with my department and talking about what we’re working on has helped my department and me stay agile. Within the BSA department, we like to let everybody know what we’re working on. I’ll be looking at something and I’ll call one of the analysts and ask, “Do you see what I’m seeing in this activity?” In one case, I recall saying, “Just in looking at the activity, I can tell you right now there are several phone lines that they’re paying for. Now, let us look at all the hotels,” I said. “I think you might be looking into a human trafficking [HT] case.” We can see money laundering, but you can also see HT activity. How did we see this? We saw this because we were keeping abreast of the HT trends.

AT: Tell us how you have built a strong team and also a strong network of professionals within the AFC industry.

(DB): I have so many years of experience in the industry—and I still have quite a few contacts from other industries and we talk about what we do with our cases. We don’t share information on filing or customer names instead we might share an incident. It is difficult but if you truly know your customer, you can say, “This looks isolated,” or “This doesn’t look right for this customer.” We’re a community bank, so I think we have the upper hand in knowing our customers’ activity because of our work on high-risk cases. I can usually look at a case and say, “This doesn’t look right, so let me see.” Or “Let me check on that.” But just talking to other people in the industry helps me know if they are seeing the same things.

I also connect with professionals at conferences. I met a victim of HT who was speaking at a local conference, and she was sitting at my table. I keep in contact with her and I can call her if I need something or if I want to know how the activity that I’m looking at can relate to HT.

One of the most important things for me as a professional is my contacts. I have contacts in the fraud department and the fraud department has even more contacts because they contact LE for their cases. We get involved at the end of the fraud case, but then we must decide if we need to file a SAR on it because they don’t file SARs, we do. In addition, we do have that connection where we can say, “Can you call so and so and see what’s going on with this case?”

AT: What do you wish you would have known when you first entered the AFC field?

DB: I wish I knew about the all-around timeline and how it affects so many amendments added to the BSA throughout the years. When I first started doing this in the ‘70s, I never imagined that financial crime would evolve into this huge, massive thing. It is constant, but it also changes. Financial crime has worsened over the years, like with the COVID-19-related fraud cases involving the loans that were going out to help companies stay afloat. We have quite a few cases like this, and it really taught us a lot.

AT: Any additional advice you would like to offer your peers who have just begun their careers or who want to transition to a different part of AFC?

DB: Learn, learn, learn. If you want to get into the BSA department, get on the internet and type it in. I say you go from there. If you have a gut feeling, go with it! If in doubt, file a SAR. It is not up to us to determine/prove a crime. Always remember that when filing a SAR, you might be providing a piece of information that may assist LE in catching the criminals.

AT: In addition to helping in the fight against financial crime, what do you like to do when you are off the clock?

DB: I enjoy being around family and I keep busy. I craft, but I also paint with watercolors. I like to paint flowers and sketch faces. I wanted to be an artist, so I went to art school at the art institute. I did not like the painting part when I started, but I love it now. I also like to sew. When I was a youngster, my grandmother started teaching me how to sew. I used to make all my clothes for school. I once made a dress that went to the State Fair.

Interviewed by: Karla Monterrosa-Yancey, CAMS, editor-in-chief, ACAMS, USA,

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