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Suspicious On-Us Checks: Possible Structuring

Question: 
We had two $9500 On-Us checks cashed a couple days apart by a 3rd party non-customer. The checks were both issued by the same construction company (our customer) and both checks were written on the same date. The fact that the individual cashed them on different days indicates possible structuring. In this scenario, would you recommend including our account holder as a suspect as well, or just the individual who cashed the checks?
Answer: 

Randy Carey: It takes two to tango. The only way the construction company was not complicit was if they had a very good business reason for issuing checks in that manner. You and I know that they do not without even asking.

Answer: 

Ken Golliher: Increasingly, I'm in favor of the theory: The customer knows. Ask him.

Not wholly unlike Randy, I would begin by assuming the customer is a SAR subject. The purpose of the phone call would be to confirm that.

First published on 01/27/2014

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