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#2080013 - 05/24/16 03:27 PM Close account?
Victoria S Offline
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Customer has requested wire to Nigeria from funds deposited to his acct yesterday. Would like to ask customer to close acct due to suspicious activity. What is the best way to present this request to customer?

Thanks.

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#2080024 - 05/24/16 03:47 PM Re: Close account? Victoria S
John Burnett Offline
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I wouldn't close the account until you've determined whether yesterday's deposit was legit or fraudulent. I'm about 95% sure it was a counterfeit check. Am I right? Who deposited the funds? Your customer or an unknown third party? Do you think his account information has been compromised, or do you just want to be rid of the customer because he's already showing signs of gullibility that could cost you money down the road?
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#2080026 - 05/24/16 03:48 PM Re: Close account? Victoria S
Big Dog Offline
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You are under no obligation to give a customer a reason for closing an account. however, if this has been a good customer who is the possible victim of a scam, better to discuss the nature of the source of the deposit and the reason for the wire, considering it is potentially not typical activity for this customer. Protect them and your bank from potential fraud loss.
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#2080061 - 05/24/16 05:10 PM Re: Close account? John Burnett
Victoria S Offline
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Joined: Jul 2015
Posts: 94
Cashier's check indicated a person with same last name of customer as the remitter. However, he indicated the money was from a church to be sent to Nigeria. Why would a church give him the money to send? He has had several wires in/out with no clear explanation of the funds. But no international monies at this point. Isn't Nigeria on the OFAC list?

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#2080062 - 05/24/16 05:11 PM Re: Close account? Victoria S
Victoria S Offline
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Thinking he may be a mule

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#2080068 - 05/24/16 05:25 PM Re: Close account? Victoria S
MScarn6942 Offline
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Does the church have missionaries down in Nigeria? Seems like potential fraud to me, but John is right, lots of questions to ask first.

Nigeria is not on the OFAC list, unless I've been using the wrong one!
https://www.treasury.gov/resource-center/sanctions/Programs/Pages/Programs.aspx
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#2080119 - 05/24/16 07:01 PM Re: Close account? MScarn6942
Victoria S Offline
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Joined: Jul 2015
Posts: 94
Thank you for the link for the OFAC list. I thought it would be a simple, straightforward list, but not so. Would it be easier to do an OFAC search on a name/country?

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#2080143 - 05/24/16 07:36 PM Re: Close account? Victoria S
thomasj Offline
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OFAC is no longer black and white, it's many different shades of gray, and not only when dealing with country sanctions. For example, an organization that is not on the OFAC list that is owned or partially owned by an SDN is could be considered blocked. OFAC screening is going to get more and more difficult.
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#2080218 - 05/25/16 03:52 AM Re: Close account? Victoria S
JacF Offline

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Quote:
Cashier's check indicated a person with same last name of customer as the remitter.

Given the high likelihood that this is a counterfeit item, I would infer that the customer's last name was used to try to make the phantom remitter appear to be credible.

Quote:
However, he indicated the money was from a church to be sent to Nigeria. Why would a church give him the money to send?

They wouldn't.

Quote:
He has had several wires in/out with no clear explanation of the funds.

I agree with your conclusion that he's a mule. Maybe willing, maybe a victim.

In any case, I recommend that you put the brakes on the wire and look into the deposited item further before releasing any funds.

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#2080250 - 05/25/16 01:09 PM Re: Close account? Victoria S
edAudit Offline
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edAudit
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You are here
is there an upside to keeping this account?
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#2080259 - 05/25/16 01:26 PM Re: Close account? Victoria S
Big Dog Offline
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No. You would need to babysit this customer for the duration of his relationship with the bank. he probably answered a "work from home" ad or something. It will just happen again.
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#2080317 - 05/25/16 03:58 PM Re: Close account? Big Dog
Victoria S Offline
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Joined: Jul 2015
Posts: 94
Good point.

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#2080320 - 05/25/16 04:01 PM Re: Close account? JacF
Victoria S Offline
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Posts: 94
All in all, he is becoming a shady character.

I realize Nigeria isn't on the OFAC list, but is on FinCen's list of Embargoed Countries. Does that mean no financial transactions are permitted?

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#2080356 - 05/25/16 05:13 PM Re: Close account? Victoria S
Big Dog Offline
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Each sanction is different. you would need to look at that program, but likely not an issue for transactions to an individual in the country.
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#2080367 - 05/25/16 05:45 PM Re: Close account? Big Dog
Victoria S Offline
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Joined: Jul 2015
Posts: 94
Thank you very much.

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