Skip to content
BOL Conferences

New Reply Thread Options
#2290280 - 10/31/23 07:14 PM Possible money laundering
Compliance Action Subscriber 1226 Offline
100 Club
Joined: Sep 2015
Posts: 211
We have a customer that only had a couple of CD accounts with the bank and then opened a checking account and deposited a large amount of money from a trust account he had with WF. This account has been open a little over two months. He has done multiple wires to according to him, a person that is going to invest the funds for him. He has done wires to other individuals and he said the funds from those wires were supposed to be transfered to the person doing his investments. He has opened checking accounts with two other banks in the area and doing the same type of transactions. and they have refused to do wires for him. We are no longer doing wires for him also. We have filed CTRs and SARs on him. He has done several cash transactions at just below the reporting amount. The bank has been contacted by an out of state bank's fraud manager asking about wires that were being sent their customer, they are suspecting fraud because this customer is not an investor. This is just a tip of about what is going on. Various conversations with our customer has resulted in detail of contact methods, purpose of wires and how instructions were received continue to change. We are at the point, do we close his account or freeze the funds until we possbily hear from FinCEN?
Last edited by Compliance Action Subscriber 1226; 10/31/23 08:53 PM.
Return to Top Reply Quote Quick Reply Quick Quote
#2290289 - 11/01/23 01:48 AM Re: Possible money laundering Compliance Action Subscriber 1226
BrianC Offline
Power Poster
BrianC
Joined: Nov 2004
Posts: 6,978
Illinois
Under what authority would you propose freezing funds in absence of a court order?

Give the customer a cashier's check and move on. (Note if they have direct deposit of federal benefits you have to provide 30 days advance notice.)
_________________________
Sola Gratia, Sola Fides, Sola Scriptura, Solus Christus, Soli Deo Gloria!
www.tcaregs.com

Return to Top Reply Quote Quick Reply Quick Quote
#2290323 - 11/01/23 07:59 PM Re: Possible money laundering Compliance Action Subscriber 1226
ACBbank Offline
Power Poster
ACBbank
Joined: Jul 2006
Posts: 4,535
New York City
You have no authority to freeze this customer's account, suspicious activity or not. You should however close the account and mail them a check.
_________________________
"100 victories in 100 battles isnt the most skillful. Subduing the other's military w/o battle is the most skillful." Sun-Tzu

Return to Top Reply Quote Quick Reply Quick Quote
#2290353 - 11/02/23 07:01 PM Re: Possible money laundering Compliance Action Subscriber 1226
HappyGilmore Offline
10K Club
Joined: Jun 2004
Posts: 20,080
Pulling people out of the ditc...
sounds like a monitoring mess, just close the account and have him take this headache elsewhere...
_________________________
Providing alternative truths since the invention of time

Return to Top Reply Quote Quick Reply Quick Quote
#2290368 - 11/03/23 12:54 PM Re: Possible money laundering Compliance Action Subscriber 1226
Anonymous
Unregistered

You should however close the account and mail them a check.

Under what pretense? If y'all keep closing accounts and sending checks, who are you going to have for customers?

Return to Top Reply Quote Quick Reply Quick Quote
#2290372 - 11/03/23 01:08 PM Re: Possible money laundering Compliance Action Subscriber 1226
Rocky P Offline
Power Poster
Joined: Jun 2003
Posts: 7,819
Florida
Profitable ones.
Any business has a risk/cost reward issue. What is the purpose of keeping a high maintenance/risk low profit customer for the sake of keeping a customer?

One bank I worked at developed a program to identify all profits from the accounts compared with the costs. We referred to it as "Rank and Yank". They determined that 20% of the customers caused the greatest risks and costs. Those were asked to leave, including some with very decent balances. Their demand for service, employee/asset costs and/or risks greatly outweighed their benefits. Reducing them actually increased deposits because staff was better utilized in serving our customers and in turn drawing in additional ones.
_________________________
Integrity. With it, nothing else matters. Without it, nothing else matters.

Return to Top Reply Quote Quick Reply Quick Quote
#2290392 - 11/03/23 06:18 PM Re: Possible money laundering Anonymous
HappyGilmore Offline
10K Club
Joined: Jun 2004
Posts: 20,080
Pulling people out of the ditc...
Originally Posted by Anonymous
You should however close the account and mail them a check.

Under what pretense? If y'all keep closing accounts and sending checks, who are you going to have for customers?
under the pretense that if it costs more to bank the client than he brings to the bank, why would i continue to bank them? monitoring at-risk clients is not a cheap process. and if i think a client is perhaps doing something illegal, why would i continue to bank them?
_________________________
Providing alternative truths since the invention of time

Return to Top Reply Quote Quick Reply Quick Quote
#2290406 - 11/03/23 09:09 PM Re: Possible money laundering HappyGilmore
Anonymous
Unregistered

Originally Posted by HappyGilmore
Originally Posted by Anonymous
You should however close the account and mail them a check.

Under what pretense? If y'all keep closing accounts and sending checks, who are you going to have for customers?
under the pretense that if it costs more to bank the client than he brings to the bank, why would i continue to bank them? monitoring at-risk clients is not a cheap process. and if i think a client is perhaps doing something illegal, why would i continue to bank them?

This is the original post:

We have a customer that only had a couple of CD accounts with the bank and then opened a checking account and deposited a large amount of money from a trust account he had with WF. This account has been open a little over two months. He has done multiple wires to according to him, a person that is going to invest the funds for him.

It appears to me, without knowing any more information, that this customer is the one being frauded or scammed. They've had "a couple" of CD's, and now a checking account, so this clearly isn't a new customer just coming off the street. And based on "transactions just under the reposting amount"", I assume this customer has MONEY, especially if funds are coming from a trust. So I think the client bring more to the bank that you think. How old is the customer? Has there been any conversations about the wires, or just assumptions? Is anyone looking out for this customer? Isn't that our job?

Close the account, give them a check, and send them packing? Is that how you treat all of the customers are your bank? How about a little compassion?

Return to Top Reply Quote Quick Reply Quick Quote
#2290407 - 11/04/23 12:59 AM Re: Possible money laundering Anonymous
Rocky P Offline
Power Poster
Joined: Jun 2003
Posts: 7,819
Florida
"Close the account, give them a check, and send them packing? Is that how you treat all of the customers are your bank? How about a little compassion?"

Reread the last 2 posts. Banks are in business to make money not to babysit for customers that cost them money and can create a regulatory and reputational risk.
_________________________
Integrity. With it, nothing else matters. Without it, nothing else matters.

Return to Top Reply Quote Quick Reply Quick Quote
#2290433 - 11/06/23 07:21 PM Re: Possible money laundering Anonymous
HappyGilmore Offline
10K Club
Joined: Jun 2004
Posts: 20,080
Pulling people out of the ditc...
Originally Posted by Anonymous
It appears to me, without knowing any more information... yes, agreed, you don't have any more information that we have, but somehow it appears that your lack of information versus our lack of information makes you right

I assume... one should never assume when making a banking decision, facts should be gathered to make fiscally correct choices

I think the client bring more to the bank that you think... and you base this thinking on what? that they have a couple of CDs and have done some wires? what it is costing for the bank to monitor this account that is making transactions "just under the reposting amount?" and monitor and counsel the client on what may be fraud?

Is anyone looking out for this customer? Isn't that our job? actually, our job as bankers is to provide a service to our clients that protects the bank and allows it to make money. yes, we have a responsibility to our clients, but at what point do you allow them to continue to hjave suspect fraud items, which, at some point, puts the bank at further risk if you continue to counsel the customer and they continue to do these?

Close the account, give them a check, and send them packing? Is that how you treat all of the customers are your bank? How about a little compassion? No one is siggesting that "all the customers at your bank" are treated like this, but ones that creat a bunch of monitoring for minimal, if any, return? yes, we would encourage them to seek a banking relationship elsewhere.
_________________________
Providing alternative truths since the invention of time

Return to Top Reply Quote Quick Reply Quick Quote
Quick Reply:
HTML is disabled
UBBCode is enabled




Moderator:  MagicCity, P*Q, Truffle Royale