Introductory BSA/AML Examiner School, Atlanta, CA

Bank of Smithville USA

Page 11

Example 1 On July 14, 2014, a CSB customer purchased a $110,000 cashier’s check, with proceeds withdrawn from a checking account. The cashier’s check was remitted by and payable to the purchaser. On June 8, 20XX, the same customer negotiated a $60,000 CSB cashier’s check, remitted by and payable to the purchaser, and dated June 14, 2014. The proceeds were subsequently used to purchase five new cashier’s checks, styled in the same manner, one in the amount of $20,000, and four in the amount of $10,000. To date, three of the $10,000 cashier’s checks and the $110,000 cashier’s check remain outstanding. Example 2 On November 22, 20XX, a bank customer purchased a $26,250 cashier’s check remitted by and payable to the customer. The cashier’s check was purchased with a $26,250 Bank of the Smith (BOS) cashier’s check, dated November 24, 2015, styled in the same manner. Further review determined the 2015 cashier’s check was purchased with 35 checks, each remitted by a BOS business customer, and each in the amount of $1,500. The remaining $26,250 was deposited into the purchaser’s BOS checking account. Of note, an additional unusual cashier’s check purchase, dated January 9, 20XX, in the amount of $29,250, was also identified. Management has filed previous SARs on the purchaser for apparent structuring activity and unusual monetary instrument purchases; however, the activity described above was not identified or reported. To date, the cashier’s checks totaling $26,250 and $29,250 remain outstanding. Example 3 On October 31, 20XX, a BOS customer conducted a $21,750 deposit, comprised of three, $7,250 BOS cashier’s checks, dated November 23, 2015. Each check was remitted by and payable to the customer. On the same day, the proceeds were withdrawn to purchase three new cashier’s checks styled in the same manner. Two of the $7,250 cashier’s checks remain outstanding. The remaining $7,250 cashier’s check was negotiated on July 7, 20XX. The customer received $1,000 cash and used the remaining proceeds to purchase a $6,250 cashier’s check styled in the same manner, which is currently outstanding. Example 4 On December 8, 20XX, a BOS customer conducted a $45,000 withdrawal to purchase three cashier’s checks in the amounts of $10,000, $15,000, and $20,000. Each check was remitted by and payable to the customer. On June 8, 20XX, each check was negotiated and used to purchase three new cashier’s checks, in the same amounts, and styled in the same manner. The customer also purchased an additional $20,000 cashier’s check, with proceeds withdrawn from a BOS checking account. Approximately one month later, July 7, 20XX, one of the $20,000 cashier’s checks was negotiated at another institution. To date, the remaining of $10,000, $15,000, and $20,000 cashier’s checks are outstanding. Example 5 On August 8, 2014, four certificates of deposits, totaling $44,730.54, were closed. The proceeds were used to purchase three cashier’s checks in the amount of $11,469.37 and one in the amount