There are many layers to this story so please bear with me while I try to simplify. While in the process of reviewing our customer's account, let's say John Doe, it was discovered that Richard Doe, John Doe's brother, is POA for John.
While reviewing the activity in John Doe's account, it was identified that third party checks are being deposited into it (never exceeding the $1k limit) as well as various checks just written to "Doe".
Outside of this, and one of my main concerns, are large cash deposits that are facilitating large ACH payments for an entirely different individual. For example, a $5,000 cash deposit followed by a $4,873.82 ACH payment to Amex for the benefit of Charles Smith. According to the branch, Charles Smith is a friend of Richard Doe, the POA, and has no connection to the account holder, John Doe. Wouldn't this constitute MSB activity through a personal account?
Thank you for your time and assistance, I appreciate it immensely!