Following a recent audit, I am looking for guidance on what exactly to select in the "Were any of the following instrument types/payment mechanism(s) involved in the suspicious activity? (Check all that apply)" in the following scenarios:
Customer deposits money (check, ACH, wire, etc.) and structures withdrawals afterwards.
The deposit itself is not suspicious (e.g. tax refund, payroll, etc.) but we do list it in the narrative to show the source of funds. The only suspicious transactions, listed in the transaction detail, are the withdrawals.
Technically, though, the deposit was "involved" in the suspicious activity in that it provided the funds for it.
Are the checkboxes referring to the deposit supposed to be checked in this section as well as "U.S. Currency"? Any guidance on this? What are others doing?
Opinions are my own.
"I was gratified to be able to answer promptly. I said I don't know." - Mark Twain