BSA/AML Examiner School - December 2022

12/1/2022

Example 4: Unknown suspect applied for membership with the Credit Union through website using DocuSign. Unknown suspect provided driver’s license using the name Bryn Todd address 123 Brightwood Drive. After becoming a member of the credit union, the unknown suspect applied for an unsecured loan in the amount of 9,000. The suspect was able to answer out of pocket security questions that only the true Bryn Todd should have been able to answer. He provided credit union with a paystub fromABC Factory. On October 1, 2019, the credit union received a call from the real Bryn Todd that he had received an alert on his credit report that we had pulled credit on him and he was not aware of it or was not affiliated with the credit union and had not applied for membership or a loan. He also went on to inform the credit union that someone had tried to secure a loan the week before at another credit union using his information. At this point, I called the number listed on the paystub to verify employment to find out that they do not have anyone working for them named Bryn Todd. The loan officer working on the loan said she had contacted the unknown suspect because there was a freeze on his credit report. HE called her back and was able to have the freeze removed and tried to proceed with the loan. I ended up having a conversation that I requested he come into the branch for additional verification before we could proceed. HE stopped calling after that. I talked to the real Bryn Todd and he sent me a copy of his DL just to see the different person on the DL with the different address. Unknown was using his SS# and Date of Birth. Filed a police report for identity theft.

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Example 5: SAR filed for suspicion concerning source of funds regarding a cash deposit by Linda Bryant into account 69654 at the main office. Bryant deposited $25,000 cash into account 69654 on 7-10-2019. The deposit was entirely comprised of $100s. Bryant is a retired county clerk. She told branch staff that the cash had been in a safe at her home and that her daughter advised she bring it in to the bank to deposit it. Regardless of whether or not the cash had been in a safe in her home, it still doesn’t explain how a retired county clerk had $25,000 in $100s to deposit.

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