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#2120258 - 03/02/17 05:06 PM MSB Activity in a Personal Account?
AML7952 Offline
New Poster
Joined: Oct 2016
Posts: 5

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!

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#2120341 - 03/02/17 11:00 PM Re: MSB Activity in a Personal Account? AML7952
ACBbank Offline
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Joined: Jul 2006
Posts: 4,159
New York City
This is a little bit to Bugs Bunny for my liking. Why even bother with this? Just close the account and be done with it.
"100 victories in 100 battles isnt the most skillful. Subduing the other's military w/o battle is the most skillful." Sun-Tzu

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#2120351 - 03/03/17 11:37 AM Re: MSB Activity in a Personal Account? AML7952
edAudit Offline
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Joined: Jul 2008
Posts: 4,765
You are here
Just close the account and be done with it.

Bingo we have a winner
Opinions can be considered as coming from anywhere but my employer.


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#2120364 - 03/03/17 01:43 PM Re: MSB Activity in a Personal Account? AML7952
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
Don't make it harder than it is. Clearly, a consumer account is being used to facilitate business activity and there is a list of reasons as to why that is unacceptable.

Tell the customer that the consumer account will be closed and that you have some questions before you will allow him to open a business account...
In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.

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