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#2181341 - 06/12/18 12:28 AM Unusual Check Fraud Situation
TryingtoComply Offline
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Joined: Apr 2013
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The West
I have an unusual situation (at least I think I do.....). We have a customer whose account is established to only accept incoming/outgoing wires. Every month we have numerous counterfeit checks hit our non-post report. There is no way that a check would ever clear the account as it is blocked.

This customer has made their account number and wire instructions available on their website to assist their clients, which is likely contributing to the problem.

In a situation like this would you file a SAR? I believe we should as it's attempted fraud. But my concern is that we will likely be filing a SAR every 90 days forever on this account.
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#2181342 - 06/12/18 01:38 AM Re: Unusual Check Fraud Situation TryingtoComply
BrianC Offline
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Joined: Nov 2004
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Illinois
Quote:
This customer has made their account number and wire instructions available on their website to assist their clients, which is likely contributing to the problem.


Time to tell them to take the website down if they want to continue banking with you (assuming the relationship is worth keeping considering the amount this will cost you in monitoring and SAR filing time).

Quote:
In a situation like this would you file a SAR?


This is not optional. If you cannot identify a subject and the amount exceeds $25,000 a SAR is mandatory.

Quote:
But my concern is that we will likely be filing a SAR every 90 days forever on this account


See note above. This is not optional, and yes you might be thanks to your customer.
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#2181352 - 06/12/18 11:59 AM Re: Unusual Check Fraud Situation TryingtoComply
TryingtoComply Offline
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Of course, I knew the answer, but I don't like the answer. I just found out about this situation and I know I have a battle ahead of me on this one. We really need to close the account and open a new one and then make the customer agree to no longer publish their account number on the website.

Thanks, for confirming what I already knew. It just feels good to know my peers agree with me!
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#2181419 - 06/12/18 04:16 PM Re: Unusual Check Fraud Situation TryingtoComply
P*Q Offline

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Somewhere
I can't possibly imagine this customer is remotely profitable for the Bank. I'd be showing them the door sooner rather than later.

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#2181509 - 06/12/18 09:47 PM Re: Unusual Check Fraud Situation TryingtoComply
TryingtoComply Offline
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They are actually a very large profitable relationship.
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#2181598 - 06/13/18 04:01 PM Re: Unusual Check Fraud Situation TryingtoComply
John Burnett Offline
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Joined: Oct 2000
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Cape Cod
You can suggest that the customer ditch the listing of routing info on its website and put in its place a statement indicating that persons interested in sending wires contact them for routing instructions.
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#2181658 - 06/13/18 06:58 PM Re: Unusual Check Fraud Situation TryingtoComply
TryingtoComply Offline
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That's what we will be doing. smile
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#2181726 - 06/13/18 11:54 PM Re: Unusual Check Fraud Situation TryingtoComply
Princess Romeo Offline

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At the very least, the customer should require their customers to "log in" to a "customer account" area of their website that contains this information. That way, it's still convenient for their customers, but (hopefully) not so convenient to fraudsters.
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#2181733 - 06/14/18 11:25 AM Re: Unusual Check Fraud Situation TryingtoComply
TryingtoComply Offline
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Joined: Apr 2013
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Update: Discovered yesterday that the account number is not actually on their website. I looked for it and found that they use a service called Flywire, an international payments solution. It's possible that their account number may have been compromised on that end. Regardless, I advised the branch that maintains the account that we will take a wait and see approach. If we have to file a supplemental SAR, I will be requesting that they close the account and open a new one just like we would with any other incident of fraud.
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