No suspect, No victim, No transaction - SAR?

Posted By: Susan

No suspect, No victim, No transaction - SAR? - 04/17/20 06:07 PM

If you have no victim, no suspect, and no actual transaction attempted at the FI, are you required to file a SAR? We have received calls from various individuals asking if the Cashier's Checks (which appear drawn on our FI) they received in the mail are valid. These are fraudulent cashier's checks being sent to non-customers - we do not know the suspect and we have no victim as the individuals are not customers; we have no transaction as they did not attempt to deposit/cash the cashier's checks at our FI. I looked at the FAQs as well as the SAR Filing Instructions and was unable to find this exact scenario discussed. My gut tells me, no SAR - since no transaction was attempted at our FI, Agree? If disagree, why?
Posted By: rlcarey

Re: No suspect, No victim, No transaction - SAR? - 04/17/20 07:04 PM

You have nothing but phone calls to date.
Posted By: RockChucker, CAMS

Re: No suspect, No victim, No transaction - SAR? - 04/17/20 08:02 PM

Susan, welcome to BankersOnline! As Randy pointed out, nothing to do at this point.
Posted By: BrianC

Re: No suspect, No victim, No transaction - SAR? - 04/17/20 08:57 PM

If those checks start trying to clear through your bank for the folks who didn't call first and the aggregate amount exceeds $25,000, then we'll have a different answer.
Posted By: Susan

Re: No suspect, No victim, No transaction - SAR? - 04/17/20 10:06 PM

Thanks all! I trust my gut, but I like to verify it sometimes. smile Have a great weekend!

@BrianC.... I agree, if we actually have attempts to deposit the story changes.
Posted By: WonderWoman

Re: No suspect, No victim, No transaction - SAR? - 05/13/20 07:23 PM

Have you seen the checks at all? I would have people send you a copy if they can. When I was regulated by the OCC we had to report the situation to them & then they published that there were counterfeits. I think(?) you have to report it to your regulator. https://www.bankersonline.com/alerts/counterfeit-cashiers-checks

Also, we posted a message on our website to try to help curb people negotiating them.