SAR for check fraud

Posted By: WIBanker91

SAR for check fraud - 03/14/18 12:35 PM

We have not had a lot of check fraud but it seems to be on the rise. Do you complete a SAR and/or Investigation for all regardless of the dollar amount? Typically they have been under $1000 and we get the account closed. For others the account is put on Positive Pay so checks may be returned, potentially taking it to larger amount.
Posted By: ACBbank

Re: SAR for check fraud - 03/14/18 01:57 PM

When you cannot identify a suspect, you don't need to file a SAR if the amount is below $25,000.
Posted By: Anonymous

Re: SAR for check fraud - 03/14/18 03:48 PM

Often checks continue to come in and they are payable to one or several people. Does that count as a suspect? The total can go over $5K including returns. How do you monitor? Do you have an incident, suspicious report from retail/operations each time? This can end up a full time job
Posted By: HappyGilmore

Re: SAR for check fraud - 03/14/18 04:09 PM

monitoring check fraud is a full time job, and should be treated as such. one of the processes you will need to develop internally is how you identify a suspect in said fraud. And are the items deposited fraudulent, or just coming back as NSF? You will need to have a step in place to monitor your accounts that you see with high numbers of these items deposited and returned, determine if they are involved in the fraud or not, if you want to keep them as customers, and many other items related to this. what internal forms or reporting you will use also needs to be determined, and whatever you choose it needs to be populated to the masses and everyone needs to use it each time - otherwise you aren't capturing your risk.
Posted By: 80's Lady

Re: SAR for check fraud - 03/14/18 04:53 PM

Are you speaking of check fraud on checks counterfeited or forged on your customer's accounts that present through inclearings, WIBanker91? There are several different types of "check fraud", so I want to be sure we are on the same page on our answers.

The mods may want to move this to the private forums for further discussion.
Posted By: JacF

Re: SAR for check fraud - 03/14/18 05:57 PM

To build on what Happy said:
A payee does not necessarily equal a suspect. The specific facts of each situation will be used to determine who are your suspects and who are your victims.

That said, your initial posts leads me to believe that the scenario that is prompting your question relates to a customer of yours having their account compromised, and counterfeit checks being distributed. If that is the case, the payees are in all likelihood victims, who have received the checks as a result of a purported mystery shopping assignment, online romance, or some other common scam tactic. Even if each of these checks is under $1000, if the aggregate total of the counterfeit checks is $25,000 or more, then you have crossed the mandatory reporting threshold.