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SAR Filing on Counterfeit Checks

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Question: 
Are banks required to file an SAR for Counterfeit Checks received, but not transacted, in the amounts over $25,000.00 if we have no information on the suspects?
Answer: 

I assume you're describing situations in which a customer brings a check to you for deposit and you determine somehow that the check is counterfeit and that your customer has been targeted as a victim in a check fraud. Unhappily, I believe you are required to file a SAR in such a case. I'd advise keeping a copy of the check in question (in case you've had to hand it back to your customer or to law enforcement) as a resource in completing the sketchy SAR you'll have to complete. The filing instructions require you to file when your institution is involved (or could have been involved) in what you suspect is illegal activity, if the amount involved is $25,000 or more, even if you don't have a suspect in mind.

First published on BankersOnline.com 8/28/06

First published on 08/28/2006

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