Watch for a customer who presents a check just under $1,000 and then declines the transaction. This behavior often signals an attempt to avoid the database entry required at $1,000. Watch for a customer who splits one transaction into smaller amounts. Watch for checks from the same customer totaling just under $1,000 with no clear reason for the split. Watch for a customer who asks what amount triggers a reporting requirement or requires ID.
\nWatch for multiple checks from the same customer on the same day totaling just under $10,000. Watch for the same customer returning on consecutive days with amounts that stay just below $10,000. Watch for multiple people presenting checks from the same employer or the same account on the same business day.
\nWatch for a customer who visits multiple times on the same day with checks from the same payor or employer. Watch for checks with consecutive numbers presented by different people on the same day. Watch for payroll check amounts or schedules that do not match the employer's apparent business. Watch for an endorsement that appears freshly written on an older check. Watch for multiple checks with identical endorsement signatures. Watch for a check made payable to one person but presented by someone else without documented authorization. Watch for repeated presentations where the named payee never appears in person.
\nWatch for an ID that does not match the customer's apparent age or physical appearance. Watch for documents with mismatched fonts, irregular lamination, or unusual holographic elements. Watch for a customer who cannot confirm basic information from their own ID. Watch for multiple customers presenting nearly identical documents on the same day.
\nWatch for a companion who directs or controls the transaction without documented authority. Watch for a customer who appears coached, reluctant to speak independently, or looks to a companion before answering. Watch for multiple checks payable to different people, all presented by one person. Watch for a customer who appears confused, disoriented, or under visible pressure. Watch for a customer who states they must cash a check and return the money to another person.
\nWatch for checks drawn on accounts associated with charitable or humanitarian organizations in sanctioned or high-risk countries. Watch for multiple individuals sharing an address or affiliation who systematically cash small checks inconsistent with normal employment. Watch for a customer whose name produces a match during OFAC screening. Watch for a customer who references sanctioned persons or organizations, or makes statements suggesting a connection to terrorism.
\nWhen you observe one or more of these indicators, complete an internal suspicious activity referral. Deliver the referral to your BSA/AML Compliance Officer by end of shift. This gives the BSA/AML Compliance Officer the time needed to review and act within the required period. You do not determine whether a report is filed — that decision belongs to your BSA/AML Compliance Officer.
", "narration_text": "Watch for a customer who presents a check just under $1,000 and then declines the transaction. This behavior often signals an attempt to avoid the database entry required at $1,000. Watch for a customer who splits one transaction into smaller amounts. Watch for checks from the same customer totaling just under $1,000 with no clear reason for the split. Watch for a customer who asks what amount triggers a reporting requirement or requires ID.\r\n\r\nWatch for multiple checks from the same customer on the same day totaling just under $10,000. Watch for the same customer returning on consecutive days with amounts that stay just below $10,000. Watch for multiple people presenting checks from the same employer or the same account on the same business day.\r\n\r\nWatch for a customer who visits multiple times on the same day with checks from the same payor or employer. Watch for checks with consecutive numbers presented by different people on the same day. Watch for payroll check amounts or schedules that do not match the employer's apparent business. Watch for an endorsement that appears freshly written on an older check. Watch for multiple checks with identical endorsement signatures. Watch for a check made payable to one person but presented by someone else without documented authorization. Watch for repeated presentations where the named payee never appears in person.\r\n\r\nWatch for an ID that does not match the customer's apparent age or physical appearance. Watch for documents with mismatched fonts, irregular lamination, or unusual holographic elements. Watch for a customer who cannot confirm basic information from their own ID. Watch for multiple customers presenting nearly identical documents on the same day.\r\n\r\nWatch for a companion who directs or controls the transaction without documented authority. Watch for a customer who appears coached, reluctant to speak independently, or looks to a companion before answering. Watch for multiple checks payable to different people, all presented by one person. Watch for a customer who appears confused, disoriented, or under visible pressure. Watch for a customer who states they must cash a check and return the money to another person.\r\n\r\nWatch for checks drawn on accounts associated with charitable or humanitarian organizations in sanctioned or high-risk countries. Watch for multiple individuals sharing an address or affiliation who systematically cash small checks inconsistent with normal employment. Watch for a customer whose name produces a match during OFAC screening. Watch for a customer who references sanctioned persons or organizations, or makes statements suggesting a connection to terrorism.\r\n\r\nWhen you observe one or more of these indicators, complete an internal suspicious activity referral. Deliver the referral to your BSA/AML Compliance Officer by end of shift. This gives the BSA/AML Compliance Officer the time needed to review and act within the required period. You do not determine whether a report is filed — that decision belongs to your BSA/AML Compliance Officer." }