Skip to content
BOL Conferences
Thread Options
#1999278 - 03/02/15 08:59 PM Cashier Check Presented and Reissued
2old2care Offline
Platinum Poster
Joined: Oct 2006
Posts: 712
PA
A customer closed out a CD three years ago. He had a cashier's check made out in his name. From time-to time he will stop in the bank, present the check and request cash (typically between $500 and $3,000 dollars) having us re-issue a new casher's check for the balance.

He understand the instrument is considered cash.

Under BSA/AML rules the following would be reason to look for money laundering:

"Cashier’s checks exchanged for other cashier’s checks in larger amounts, adding additional cash or instruments to make up the difference."

It is "believed" he is hiding money in a divorce settlement.

Would these transaction be considered items to be logged for BSA purposes? The balance of the cashier's check is $52,000.

The customer has other accounts with the bank. He has been a bank customer for many years. All other accounts have been reviewed with no suspicious activity.

Thoughts?





Return to Top
BSA/AML/CIP/OFAC Forum
#1999286 - 03/02/15 09:14 PM Re: Cashier Check Presented and Reissued 2old2care
Elwood P. Dowd Offline
10K Club
Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
Without commenting on whether a cashiers check is "cash" in any context, I think you will find that the record retention requirement is triggered by the purchase of a monetary instrument with "currency." A cashiers check does not fit the definition of "currency" and purchasing a monetary instrument with another monetary instrument does not generate a record retention requirement.

You will find other threads here that debate whether the activity is reportable as "suspicious," but those threads generally end with the observation that the bank could prohibit the activity if it chose to. So, continuing to allow it then worrying over whether it is suspicious is a self inflicted wound.
_________________________
In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.

Return to Top

Moderator:  Andy_Z