Question:
Recently we had a situation where, after opening a business checking account, it was discovered that some of the documents used to open the account were fraudulent (i.e. Articles of Incorporation, Certificate of Good Standing). The discovery was made within the 30-day new-account period. The account was restricted at the time of the discovery and the customer was informed simply that there were some "discrepancies" that needed to be resolved before the restricted status would be removed. About $7500 (gained from checks deposited) was available in the account at this time. In a situation like this, should we contact law enforcement or is filing a SAR sufficient? How long can we restrict the account/hold the funds? And if the customer produces legitimate documents to replace the fraudulent ones, are we required to lift the restriction even though something fishy is going on here?
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