BSA/AML Examiner School - December 2022

12/1/2022

Example 2: On 4/10/2019 Bethany Walker came into the branch and wanted to withdraw $20,000 from her IRA. She requested a cashier’s check payable to Tashia Braden in the amount of $19,500 and the remaining amount was deposited into her checking account. Linda Mulberry, the BSA officer, questioned Bethany about the recipient of the cashier’s check to make sure that Liz knew the recipient. She stated, “everything was good and there was nothing to worry about.” On 4/15/2019 Bethany Walker came into the branch and wanted to withdraw $22,000 from her IRA. Bethany requested the cashier’s check payable line be left blank. Mulberry explained to her that we must make the cashier’s check payable to someone. She then requested it to be made payable to herself from her IRA. She asked Donna Taylor, the cashier, if this cashier’s check would be accepted at any other financial institution. Donna said that it would. On the same day, our bank was contacted by XX Bank to verify that the cashier check was issued to Bethany. She stated it was red flagged because it was issued payable to herself from her IRA and she was attempting to deposit it into an account for Tashia Braden. Tashia Braden is a customer at XX Bank, but the person verifying the check was not familiar with this customer or activity. On 4/16/2019 Bethany Walker came into the branch and deposited the $22,000 cashier’s check made payable to herself into her checking account and had a cashier’s check issued to Tashia Braden for the amount of $22,000.

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Example 3: Steve Garrett has been an established customer since July 22, 2012. He is the director of the Bracken County Council. Mr. Garrett’s account was showing up on the Check Kitting report through the bank’s automated monitoring system that is looked at daily. The BSA Officer Linda Mulberry pulled his activity on his account for January 2020 and February 2020 and a lot of cash was involved. The month of January 2020 a total of $28,689.00 in cash and for February 2020 a total of $18,630.00 of cash was deposited into his account. When reviewing the activity on his account the deposit would include a check from XX Bank or YY Bank, or it would only be a cash deposit. Then when reviewing the account, he would write a check from the ZZ Bank, which he would always go through the drive thru window. On February 25, the BSA Officer Mulberry contacted Steve and told him we would no longer accept check on XX Bank or YY Bank. Once he was contacted on the 25th couple days later he hasn’t shown up on the Check Kitting report through the automated monitoring system.

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