We closed a customer's accounts/relationship several months ago due to account abuse. The customer continues to periodically write checks in the $3000-5000 range against her closed account. We return the checks as "closed account." Is there a check fraud filing obligation? Or is it a civil matter between the ex-customer and her payees, for her writing them bad checks?

That is check fraud and requires a SAR if over the threshold. You might want to file a report with the local police also.

If, for example, the former customer draws a number of these checks against the closed account, and the total of the checks exceeds the reporting threshold, you should file. Once you've filed, you should consider filing with the local police (even though whoever is receiving the checks back unpaid is likely to have filed a complaint with the police, too).

Would a similar version be true - if other perpetrators are using the closed account number to circulate fraudulent checks and they hit the non-post report and are returned for "closed account"?

We are have having discussions with our Deposit Ops folks about reporting these incidents to BSA/Fraud Management when exceeding the SAR reporting threshold.

In such a case, Ann, if you don't know who the "perp" or "perps" are, you would file if the aggregated attempts crested the $25,000 reporting threshold when you don't have a subject but it's apparent you're dealing with a single perp or perp group.

Thanks, John for reminding me about the higher threshold for no identified subject.