Thread Options
#2222593 - 09/30/19 01:53 PM Unknown or Known Suspect
WDCA Offline
Member
Joined: Nov 2015
Posts: 66
If we received a wire transfer request from our “innocent and naïve” customer that was identified as a scam by our fraud team, would the recipient’s (scammer’s) unverified first and last name, address, and account number used on the wire request form by our customer establish a “known” suspect? I'm trying to determine appropriate threshold for reporting. Thank you

Return to Top
BSA/AML/CIP/OFAC Forum
#2222606 - 09/30/19 03:22 PM Re: Unknown or Known Suspect WDCA
NatalieJ BSA Offline
Junior Member
Joined: Apr 2016
Posts: 40
Hello WDCA,

That is, in my humble opinion, a "grey area" scenario. If your fraud team's investigation leads you to believe that your known customer is truly not involved in the fraud, but the wire recipient is, then I'd say yes- proceed with the recipient's info and then include a detailed narrative to clearly identify the roles of all parties involved.

Return to Top
#2222659 - 09/30/19 08:08 PM Re: Unknown or Known Suspect WDCA
ColoradoAML Offline
100 Club
Joined: Mar 2018
Posts: 240
I would consider that a known suspect. I gather we're relatively conservative in this regard, but generally if we have a name, we have a suspect.

Return to Top
#2222665 - 09/30/19 08:34 PM Re: Unknown or Known Suspect WDCA
ZmbRzr Offline
100 Club
ZmbRzr
Joined: Nov 2011
Posts: 116
Arkansas
It would depend on the circumstances behind the wire. In a typical Craigslist scam where someone is instructed to deposit a check and then wire out a sum of money, it's really hard to determine whether or not any of the info your customer has received is legitimate. If it was one of those cases, I would consider it an unknown suspect.

Return to Top
#2222678 - 09/30/19 09:54 PM Re: Unknown or Known Suspect WDCA
ColoradoAML Offline
100 Club
Joined: Mar 2018
Posts: 240
I may have been answering a different question than what was asked, but it doesn't change my answer.

To determine whether we have a subject, we rely only on a name, no other PII.

To determine whether a non-customer payee of a wire or check or whatever is a subject or just another victim/money mule, unless we have a specific reason to believe that they are not the subject and therefore have not benefited or attempted to benefit from stolen funds, they're a subject. Being a money mule is illegal after all, whether wittingly or unwittingly. I agree that most of the time the beneficiary of these transactions is likely just another victim, but for our purposes I don't feel good just relying on likelihood.

If they're innocent, that should be law enforcement's job to sort out. Maybe it's just more SAR noise, but you may be providing some information that fits into a larger pattern that you can't see.

Return to Top
#2222701 - 10/01/19 01:55 PM Re: Unknown or Known Suspect WDCA
WDCA Offline
Member
Joined: Nov 2015
Posts: 66
Thanks for the responses. From what I gathered, the appropriate threshold for reporting would be 5000 even when we only have an unverified name of a suspect. I was hoping to find a definition of known suspect that would suggest needing more certainty on the suspects identity in order to be labeled known - and triggering the lower 5000 threshold. Thanks

Return to Top
#2222747 - 10/01/19 06:20 PM Re: Unknown or Known Suspect WDCA
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 39,408
Cape Cod
I'd go with the $5,000 trigger even if you feel the ID info is spurious. After all, someone is attached to the other end of the transfer, whether or not the name at that end is bogus. Even the bank and account number the transfer went to can help financial forensic investigators ferret out other information.
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top

Moderator:  Andy_Z