Violations aggregating $25,000 or more regardless of a potential suspect.
Whenever the
bank detects any known or suspected Federal criminal violation, or pattern of criminal
violations, committed or attempted against the bank or involving a transaction or
transactions conducted through the bank and involving or aggregating $25,000 or more
in funds or other assets, where the bank believes that it was either an actual or potential
victim of a criminal violation, or series of criminal violations, or that the bank was used
to facilitate a criminal transaction, even though there is no substantial basis for
identifying a possible suspect or group of suspects.
My understanding is that the trigger is based on a transaction or
attempted transaction. You say no transaction was attempted, they only sought information. I don't know that I would file on this. I would however have the account flagged for ID theft activity, and use the experience as a training for the employees that "fell" for it!
Obviously, if they attempted to advance the amount available and it in aggregate exceeded $25,000, then I would definitely file.
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