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

1 - Payee is a possible money mule, therefore presumed to be a victim not a suspect.
This may be true but it doesn't sound like you have evidence to support it. Additionally, money mules are acting illegally to launder money on behalf of someone else, so in my opinion they should be listed as a subject regardless.

2 - Why would a forger this sophisticated use their real name or identity as the payee? Our presumption would be that the forget didn't do so.
A bad forger would do this, and I'm sure that like most banks you've seen plenty of altered checks where exactly this happened. Regardless, if it was not the forger, see #1.

3 - Customer has made the additional claim that even the payee's endorsement is forged - which means the payee is not a confirmed suspect of criminal activity.
I would not defer to the customer in this.

4 - although each check is payable to the same payee, every single signature on the back is different, and, they cleared through various banks in various cities. So the payee is assumed to point towards one or more unknown criminals, rather than directly to any real person named on the face of the check.
This is often the case in mobile bank fraud, but again, see #1.

In my opinion, this is a SAR. The payees all likely benefitted from the fraudulent checks, whether they themselves created the checks or under what pretenses they negotiated them (or possibly more likely, under what pretenses someone else negotiated them on their behalf). If it's just a synthetic identity operated by a criminal, you don't have evidence of that and it's for law enforcement to discover, which they can only do if you give them the information you have.

I also think that everything you listed for remediation is appropriate. You have a system of internal controls, but they failed due to an employee's inaction, and that employee has been counseled and retrained. You can consider whether there are any procedural changes you need to make to avoid this again, but there may not be. This is hardly a systemic issue, and trying to explain it away after the fact (that may not be a fair interpretation of your question, but an examiner may review this non-file and view it that way) is likely to draw more criticism than just resolving it, documenting it and moving on.