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In Response To:
Thread Starter: praBSA
Title: Re: Who is the suspect on unauthorized checks?

There are a lot of questions here for me. When was the bank notified of the of the customer's claim? Why did the bank allow the customer's account to stay open if checks were continuously being forged? Why was the bank not rejecting the checks as fraud?

I would say if the payee is the same on every check, the payee on the check is your identified suspect if the name is legible. It's not up to you to decide if the payee is a victim or not, that would be up to law enforcement to decide. Your 1-4 are purely speculative in my opinion. 3&4 seem to have a little weight but the payee is the same. Most small dollar SARs aren't even picked up, it would be for the benefit of local law enforcement if they so choose to look for it as I would assume the customer filed a police report.

From my experience, it's better to file the SAR if necessary, better late than never. Identify the control gap/training, as you mentioned above, fix the problem so it doesn't happen again, and you won't have any problems with regulators, IMHO.