I'm trying to find out what other bank's do in circumstances involving returned counterfeit checks drawn off your institutions cashier's check/money order account.
We are trying to determine when and if a SAR filing, or a continuing SAR when applicable, is necessary for these instances; for example: 1) matching remitters/payees are less than $5,000.00 for a pre-determined time period, 2) total of all checks are less than $25,000.00 for a pre-determined time period, or 3) do we need to file at all if we do not suffer a loss and cannot determine if the remitters/payees are the scammers or if they are the victims.
Any advice, comments, or guidance references are welcome. Thanks.
1 and 2. If you can identify a subject for the filing, the trigger amount is $5,000. If you cannot, the trigger is pulled at $25,000. You may pull the trigger and file for lesser amounts.
3. The "no harm no foul rule" most definitely does not apply. The requirement is that the fraud, theft, etc., is attempted or conducted through your bank or an account at your bank. So you file even if you lose nothing.
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