Skip to content
BOL Conferences
Thread Options
#2285695 - 06/20/23 07:48 PM Combine SARs for multiple fraud?
Susan Offline
Member
Joined: Mar 2018
Posts: 89
We have multiple fraudulent checks presented against several different legal entities' accounts, all owned by the same people and with the same address. No suspicion of our customer's activity. With one exception, the fraudulent checks all appear to have the same layout, typeface, font, etc., as if they were done by the same person or organization; they also have the same fake signature. I suspect the theft of legitimate checks from a common postal mail drop. My inclination is to combine the cases and thus the SAR into one, since I suspect the fraudulent checks were created by the same people. Not everyone in the department agrees with that approach.

What have you done, in similar situations? I figured with as much check fraud as there is, that somebody else has been in the same situation.

Return to Top
BSA/AML/CIP/OFAC Forum
#2285698 - 06/20/23 07:56 PM Re: Combine SARs for multiple fraud? Susan
HappyGilmore Offline
10K Club
Joined: Jun 2004
Posts: 20,075
Pulling people out of the ditc...
first of all, you should by now who in your department will likely agree with you and who won't, so moving forward you should only ask those you know that will agree with you. saves a lot of time and heck, who needs differing opinions or negative nellies anyway!

okay, just kidding...

you don't have a known suspect, but the target is multiple accounts owned by the same legal entity. i see no reason you would not combine them, assuming there is a parent/child relationship on the accounts in your system. it may also get you to the proper threshold for reporting when there is no known suspect.
_________________________
Providing alternative truths since the invention of time

Return to Top
#2285742 - 06/21/23 04:54 PM Re: Combine SARs for multiple fraud? Susan
ColoradoAML Offline
Gold Star
Joined: Mar 2018
Posts: 391
I agree with Happy and would add that we have had cases where completely unrelated customers are victims of fraud and had evidence the fraud was perpetrated by the same unknown criminal(s). This has included check fraud with identical stock/signatures. We do combine those cases and it's our view that doing this and sharing the specific indicators with law enforcement is more useful than just filing (and not filing based on thresholds) dozens of desperate cases.

Return to Top

Moderator:  Andy_Z