Thread Starter: Anonymous
Title: Re: Who is the suspect on unauthorized checks?
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In similar situations (and we have seen a lot lately due to mailbox fishing/theft) we consider the payee to be a subject if they deposited the check, and would use $5,000 as the threshold.
As far as the timing, just file the SAR ASAP. Do all the stuff you said you were going to do to keep this from happening again. If you get a lot of other fraud reports from employees and this was a one-off missed internal communication failure I don't think you will be criticized. And that assumes this SAR will even be scrutinized in the first place. We have customers that don't report check fraud until months later so such a gap between the suspicious activity date and filing date isn't unusual -- except for the fact that you have an employee who was actually aware early on.
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