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#2167998 - 03/14/18 12:35 PM SAR for check fraud
WIBanker91 Offline
100 Club
Joined: Nov 2011
Posts: 182
We have not had a lot of check fraud but it seems to be on the rise. Do you complete a SAR and/or Investigation for all regardless of the dollar amount? Typically they have been under $1000 and we get the account closed. For others the account is put on Positive Pay so checks may be returned, potentially taking it to larger amount.

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#2168025 - 03/14/18 01:57 PM Re: SAR for check fraud WIBanker91
ACBbank Offline
Power Poster
Joined: Jul 2006
Posts: 4,260
New York City
When you cannot identify a suspect, you don't need to file a SAR if the amount is below $25,000.
"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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#2168095 - 03/14/18 03:48 PM Re: SAR for check fraud ACBbank

Often checks continue to come in and they are payable to one or several people. Does that count as a suspect? The total can go over $5K including returns. How do you monitor? Do you have an incident, suspicious report from retail/operations each time? This can end up a full time job

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#2168104 - 03/14/18 04:09 PM Re: SAR for check fraud WIBanker91
HappyGilmore Offline
10K Club
Joined: Jun 2004
Posts: 19,658
Pulling people out of the ditc...
monitoring check fraud is a full time job, and should be treated as such. one of the processes you will need to develop internally is how you identify a suspect in said fraud. And are the items deposited fraudulent, or just coming back as NSF? You will need to have a step in place to monitor your accounts that you see with high numbers of these items deposited and returned, determine if they are involved in the fraud or not, if you want to keep them as customers, and many other items related to this. what internal forms or reporting you will use also needs to be determined, and whatever you choose it needs to be populated to the masses and everyone needs to use it each time - otherwise you aren't capturing your risk.
Providing alternative truths since the invention of time

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#2168122 - 03/14/18 04:53 PM Re: SAR for check fraud WIBanker91
80's Lady Offline
Gold Star
Joined: Apr 2007
Posts: 295
Are you speaking of check fraud on checks counterfeited or forged on your customer's accounts that present through inclearings, WIBanker91? There are several different types of "check fraud", so I want to be sure we are on the same page on our answers.

The mods may want to move this to the private forums for further discussion.
I use to think I was a smart cookie before I started working in Compliance. Now, I have mastered the art of the blank stare!

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#2168157 - 03/14/18 05:57 PM Re: SAR for check fraud WIBanker91
JacF Offline

Power Poster
Joined: Nov 2001
Posts: 6,719
To build on what Happy said:
A payee does not necessarily equal a suspect. The specific facts of each situation will be used to determine who are your suspects and who are your victims.

That said, your initial posts leads me to believe that the scenario that is prompting your question relates to a customer of yours having their account compromised, and counterfeit checks being distributed. If that is the case, the payees are in all likelihood victims, who have received the checks as a result of a purported mystery shopping assignment, online romance, or some other common scam tactic. Even if each of these checks is under $1000, if the aggregate total of the counterfeit checks is $25,000 or more, then you have crossed the mandatory reporting threshold.

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