I have a scenario and a question please.
First the scenario.
Jane Doe brought a cashier's check in the amount of $36,000 from another bank into one of our branches last April. She used that to get $9,999 cash back, a $2,500 cashier's check made payable to her son, a $2,500 cashier's check made payable to her daughter, and a cashier's check for the balance (we'll say $21,000 for brevity) made payable to herself. Every red flag I own went off, so I track the cashier's check to Jane Doe.
In July Ms. Doe comes back with the $21,000 cashier's check. She gets $3,000 cash and another $18,000 cashier's check.
Now she has come back again in October with the $18,000 cashier's check she obtained in July. She once gain gets $3,000 cash and now a new $15,000 cashier's check.
I think this is suspicious. I also think it's at least potential or consistent with attempted structuring. However, my boss thinks that because "it's only $3,000" and "it's three months apart" that it's not structuring. So, I told her I would ask some experts for their opinions. I know the opinion that people use cashier's checks as defacto savings instruments. Is that the way I should look at this instead of my pessimistic view that the customer who took $9,999 originally is engaged in structuring?
Policy Question -
I'm not a fan of allowing anyone to "nibble" cashier's checks by getting some cash and a new cashier's check for a smaller amount. I want to change our policy to reflect that unless we are unable to cash the check, that we will not allow this practice. In essence, I want our policy to say that a person's choices are to either deposit the cashier's check or cash it. My boss (management) doesn't really like that idea. So again, I'm left to ask others - is that extreme? Is that common? If you have that policy at your bank, how do you have your frontline staff explain it to customers?
Thanks in advance.
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