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SAR - Our Bank Name Printed on Counterfeit Checks

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Question: 
I have a question about whether or not we need to file a SAR. Just recently we became aware that the name of our bank has appeared on counterfeit checks originating from a work-from-home scam that some people are responding to. We have been working with the FBI on this case, giving them as much information as we can. The checks don’t look anything like ours and the routing number and account numbers on the checks do not come close to our institution. The people who are receiving these checks are not our customers and the only way we are finding out about these checks is when someone tries to cash the check at one of these check cashing places. The check cashing places know not to call the phony 800 number on the check, but to look up our bank in the phone book and that is when we tell them it’s not our check, but a counterfeit. The little information we have gathered on who is doing this is most likely pseudo information such as their names and addresses and the addresses we do have are in Canada. People are faxing us copies of these checks a few times a week from all over the states. Are we required to file a SAR in this situation?
Answer: 

I think you have a crime (counterfeiting) committed at or through the bank with a potential loss exposure of more than $25,000 so even with no known suspects I think you have a SAR obligation.

First published on BankersOnline.com 6/05/06

First published on 06/05/2006

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