Should we report this?
This longtime FSCB customer visits his safe deposit box monthly.
No. This activity is not suspicious.
This longtime FSCB customer conducts a withdrawal on Monday in the amount of $9,000.00 and states she is purchasing a vehicle. She again visits your branch on Thursday and withdrawals additional $7,000.00.
Yes. This is structuring and should be reported to Financial Crimes by completing a SAR.
A tattoo parlor has a bank account at both FSCB and a neighboring bank. The business begins writing checks back and forth between FSCB and the neighboring bank, each check for the same or similar amount. Checks are clearing on the same day or the following day. The collected balance usually remains in the negative.
This is check kiting. This occurs with someone takes advantage of the 'float time' of a check clearing. This activity should be reported to Financial Crimes by completing a SAR.
When an elderly customer is accompanied by a younger person who insists on speaking for them and seems to rush the transaction. Staff should consider what as a possibility?
1. Customer not allowed to speak
2. Individual is rushing the transaction.
Staff should consider that this may be elder financial exploitation and notify Financial Crimes by completing a SAR. It is also beneficial to complete a report to the Missouri Department of Health & Senior Services.
This longtime FSCB customer, known for bi-weekly $200.00 withdrawals, raises red flags when he begins making larger, more frequent withdrawals without explanation—alongside multiple debits to cryptocurrency websites
Yes! This change in behavior may indicate the involvement in a scam.
No. This activity is not consistent with structuring as the initial deposit of $23,000.00 would have triggered a CTR. Only if additional, smaller withdrawals are conducted should this activity be reported to Financial Crimes by completing a SAR.
A husband and wife have both a joint checking account and a personal account for each. In the husbands account, you note Cash App and Venmo transactions, both incoming and outgoing and appear to be several thousands of dollars in transactions. The husband's occupation is a truck driver.
This activity may indicate the husband is acting as a money mule. Red flags to note: the occupation does not align with transactional activity and the Cash App and Venmo debits followed by the credits.
An elderly customer is suddenly unable to pay bills or buy essentials, despite having sufficient funds. This may suggest what?
1. Customer's account appears to be under the control of another.
Staff should consider this as elder financial exploitation. This activity should be reported to Financial Crimes by completing a SAR.
A non-customer visits your branch to open a checking account. The individual states he has a check that needs to be deposited. The check is from 123 Construction, LLC with an address of 379 Sandpiper Lane, Naples, FL. The check is in the amount of $7,500.00. The non-customer also mentions he will need to send a wire to his longtime friend located in Washington State to assist with medical expenses.
Yes! There are numerous red flags, consistent with money laundering.
This newly onboard customer visits your branch and inquiries about the reporting threshold. You explain the reporting threshold is $10,000.00. The customer then deposits $9,999.00.
Yes! The customer inquired about the reporting threshold and then conducted a cash deposit just beneath the reporting threshold. Notify Financial Crimes by completing a SAR.
While conducting a withdrawal for a longtime FSCB customer, you notice that the typical large balance averaging $165,000.00 is now $1,579.69. You note other large withdrawals as well as ACH debits to various crypto currency websites. When further probing questions are asked, the customer provides a screenshot of his balance on a crypto website. He explains he was setup with an investor who has more than tripled his investments.
This activity may indicate the customer is involved in a pig butchering scam. Scammers will 'fatten the hog' by taking money from the victim and "investing" in crypto. The victim is provided a fake website to track their investments. Before the victim can withdrawal the funds/benefit from the investment, the website disappears, and all communication is dropped. This activity should be reported to Financial Crimes by completing a SAR.
This longtime customer has visited your branch 6 times over the last 2 weeks. He has conducted large cash withdrawals at each visit and has not provided a withdrawal purpose. Each withdrawal is over the CTR reporting threshold and funds in the account have been collected for an extended period of time.
1. Frequent and abnormal branch visits
2. Large sum of cash being withdrawn
This activity may indicate the customer is involved in a scam or possibly may be being financially exploited. This activity should be reported to Financial Crimes by completing a SAR.
While scrolling Facebook, you see an article from the local paper of a man charged with 5 counts of wire fraud. In the article, it mentions some activity that took place at FSCB.
Yes! This activity should be reported to Financial Crimes to conduct a thorough review of the activty.
The mayor of your town brings in a cash deposit of $13,000.00 into his personal account. When you ask for his ID, he asks why you need that. He is the mayor, of course you know who he is. You explain you need the ID to complete the CTR. He then asks for $5,000.00 of the cash back and states he forgot he needed to keep some cash on hand.
Yes! This activity is consistent with structuring and should be reported to Financial Crimes by completing a SAR.
A longtime FSCB customer visits your branch and is more talkative than normal. She freely shares that Johnny Depp has recently reached out to her and has begun sending her money to cover her bills. She then states that she is helping him in return by sending some of the funds to his friends located in North Dakota and California.
This activity may indicate the customers involvement in a money laundering scam by acting as a money mule and should be reported to Financial Crimes by completing a SAR.
A longtime business customer has several hotels in your town and neighboring communities. You notice that the several members of the hotel staff come in and to deposit payroll checks. You do a review of each account and note that there is minimal account activity. Once deposits are made, the majority of the funds are sent through Cash App to the same individual, the hotel manager. There are also small transactions for the purchase of crypto. This activity is consistent with all employees of the hotel. You also notice that the staff all have the same address as the hotel.
1. Employees share an address with the hotel
2. Minimal transactions appear to be for the benefit of the customer.
This activity may indicate that the employees of the hotel are potential victims of human trafficking. This activity should be reported to Financial Crimes by completing a SAR.
The owner of a construction company has visited your location every Friday for the past several years and withdrawals $11,000.00 - $15,000.00. The company owner states that the cash is for payroll.
Yes! This is potential tax evasion.
While completing a withdrawal for $3,000.00 for a longtime FSCB customer, you note three other cash withdrawals, each for $3,000.00 within the last 2 weeks.
Yes! This activity is consistent with structuring and should be reported to Financial Crimes by completing a SAR.
A local nail salon begins depositing large sums of cash weekly, averaging $22,000.00 each week. You do a quick review of other nail salon accounts and see that this cash activity is excessive and does not align with peer businesses.
This is money laundering. Criminals need to get their 'dirty money' into the financial institution. It is often done by comingling legitimate funds with the dirty money. You can often see this by comparing peer businesses. If the spike in cash deposits is unable to be explained, please notify Financial Crimes by completing a SAR.
A customer's daughter calls in and asks for her name to be removed from her mother's account. She believes her mother is involved in a romance scam and she does not want to be involved as her mother will not listen to her concern.
1. Alarming comment made by daughter
Staff should consider that the information provided by the daughter may be factual and conduct a review of the account. Staff should look for out of the norm transactions, apparent gift card purchases, changes in email address, phone numbers etc. Activity should be reported to Financial Crimes by completing a SAR.