#1567830 - 06/21/11 07:27 PM
Re: SAR filing for internal fraud
JacF
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Diamond Poster
Joined: Aug 2006
Posts: 2,407
Midwest
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On the surface this may not appear to be criminal or an attempt to be anything other than lazy... but are you sure? Sorry to play devil's advocate for a moment, but how do we know your ostensibly lazy, corner-cutting employee isn't actually part of an ID theft ring as the inside man? Was there anything (like a debit card or check order) sent out shortly before or shortly after this address change to the "new" address? Has the account been monitored closely for any unusual activity? Was the address changed again since this incident or shortly before this incident? Has the customer been contacted? Is the customer actually at this "new" address? This isn't just laziness... it's signature fraud, which is a crime. Any crime by an insider is required to be SAR'ed. This isn't just some internal "sign up your email address" form, this is a change of address form, which should be a very closely monitored control point of your operations department. Your bank's ID Theft/Red Flags policy most likely touts your change of address forms requiring customer signature as the way you control the file maintenance changes and the integrity of your data. It's part of the heart and soul of your BSA program. If you have employees forging these, you have no control and no integrity in your system. Have you gone back and analyzed all change of address forms that this employee may have been involved with to determine if these are all actual customer signatures? I think there's a lot more investigating to be done. Especially since the employee fessed up pretty quickly, I'd be suspicious what *else* they may have done that they are now attempting to not draw attention to. If this decision were mine to make, I would definitely recommend immediate termination of this employee, retraining of all other employees, and a SAR filed immediately: you're already technically outside your timeframe window for SAR filing on this.
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