BSA-AML Examiner School eBook

Internal Use Only

Example 1:

On 7/6/17 Gene Smith had an ATM Point of Sale at 8:00 pm at Marathon 6857 Versailles, West Virginia, for the amount of 35.89. On 7/10/17 a transaction was blocked as fraud for use at Marathon 1887 Versailles, West Virginia, Gene Smith. On 4/23/17 Mitch Lee had an ATM Point of Sale at 10:44 pm at Marathon 6857 Versailles, West Virginia, for the amount of 25.10. On 5/4/17 2:15 pm Marathon 1887 Versailles, West Virginia ATM Point of Sale for 55.00 Mitch Lee. A dispute was filed. On 4/29/17 Berry Levey had ATM Point of Sale for 53.90 at 8:27 am McDonalds 415 Versailles, West Virginia, which is the same store as Marathon 6857 Versailles West Virginia. On 5/15/17 a transaction was blocked as fraud at Marathon 1887 Versailles, West Virginia, Berry Levey. On 7/14/17 an ATM Point of Sale at 7:22 pm Marathon Petro 6857 Versailles, West Virginia for 33.99 Mitch Lee. On 7/20/17 ATM Point of Sale at 8:26 pm Marathon 6857 Versailles, West Virginia for 55.00 Mitch Lee. A dispute was filed. All debit Cards for each member has been blocked and new ones ordered.

Internal Use Only

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.