{ "body_html": "

Recognizing Suspicious Activity

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Watch for these red flags during every transaction. When you see one, act immediately.

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Structuring and Avoidance

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    \n
  1. Flag a customer who presents a check just under $1,000 and then cancels.
    2. \n
  2. Flag a customer who splits one transaction into smaller amounts.
    3. \n
  3. Flag multiple checks from the same customer totaling just under $1,000 with no clear reason for the split.
    4. \n
  4. Flag a customer who asks what amount triggers a report or requires ID.
    5. \n
  5. Flag multiple checks from the same customer on the same day totaling just under $10,000.
    6. \n
  6. Flag the same customer returning on consecutive days with amounts that stay just below $10,000.
    7. \n
  7. Flag multiple people presenting checks from the same employer or account on the same business day.
    8. \n
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Check Fraud Indicators

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    \n
  1. Flag consecutive check numbers presented by different people on the same day.
    2. \n
  2. Flag payroll amounts that do not match the employer's apparent business.
    3. \n
  3. Flag an endorsement that looks freshly written on an older check.
    4. \n
  4. Flag multiple checks with identical endorsement signatures.
    5. \n
  5. Flag a check payable to one person but presented by someone else without documented authorization.
    6. \n
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ID Problems

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    \n
  1. Flag an ID that does not match the customer's apparent age or physical appearance.
    2. \n
  2. Flag documents with mismatched fonts, irregular lamination, or unusual holographic elements.
    3. \n
  3. Flag a customer who cannot confirm basic information from their own ID.
    4. \n
  4. Flag multiple customers presenting nearly identical documents on the same day.
    5. \n
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Coercion and Third-Party Control

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    \n
  1. Flag a companion who directs the transaction without documented authority.
    2. \n
  2. Flag a customer who looks to a companion before answering questions.
    3. \n
  3. Flag a customer who appears confused, disoriented, or under visible pressure.
    4. \n
  4. Flag a customer who states they must return the cashed funds to another person.
    5. \n
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OFAC and High-Risk Indicators

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    \n
  1. Flag checks drawn on accounts associated with charitable organizations in sanctioned or high-risk countries.
    2. \n
  2. Flag a customer whose name produces an OFAC match.
    3. \n
  3. Flag any customer who references sanctioned persons, organizations, or suggests a connection to terrorism.
    4. \n
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What to Do

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    \n
  1. Complete an internal suspicious activity referral.
    2. \n
  2. Deliver it to your BSA/AML Compliance Officer by end of shift.
    3. \n
  3. Do not decide whether a report is filed — that decision belongs to your BSA/AML Compliance Officer.
    4. \n
", "narration_text": "Watch for these red flags during every transaction. When you see one, act immediately.\r\n\r\nStructuring and Avoidance\r\n\r\nFlag a customer who presents a check just under $1,000 and then cancels.\r\nFlag a customer who splits one transaction into smaller amounts.\r\nFlag multiple checks from the same customer totaling just under $1,000 with no clear reason for the split.\r\nFlag a customer who asks what amount triggers a report or requires ID.\r\nFlag multiple checks from the same customer on the same day totaling just under $10,000.\r\nFlag the same customer returning on consecutive days with amounts that stay just below $10,000.\r\nFlag multiple people presenting checks from the same employer or account on the same business day.\r\n\r\nCheck Fraud Indicators\r\n\r\nFlag consecutive check numbers presented by different people on the same day.\r\nFlag payroll amounts that do not match the employer's apparent business.\r\nFlag an endorsement that looks freshly written on an older check.\r\nFlag multiple checks with identical endorsement signatures.\r\nFlag a check payable to one person but presented by someone else without documented authorization.\r\n\r\nID Problems\r\n\r\nFlag an ID that does not match the customer's apparent age or physical appearance.\r\nFlag documents with mismatched fonts, irregular lamination, or unusual holographic elements.\r\nFlag a customer who cannot confirm basic information from their own ID.\r\nFlag multiple customers presenting nearly identical documents on the same day.\r\n\r\nCoercion and Third-Party Control\r\n\r\nFlag a companion who directs the transaction without documented authority.\r\nFlag a customer who looks to a companion before answering questions.\r\nFlag a customer who appears confused, disoriented, or under visible pressure.\r\nFlag a customer who states they must return the cashed funds to another person.\r\n\r\nOFAC and High-Risk Indicators\r\n\r\nFlag checks drawn on accounts associated with charitable organizations in sanctioned or high-risk countries.\r\nFlag a customer whose name produces an OFAC match.\r\nFlag any customer who references sanctioned persons, organizations, or suggests a connection to terrorism.\r\n\r\nWhat to Do\r\n\r\nComplete an internal suspicious activity referral.\r\nDeliver it to your BSA/AML Compliance Officer by end of shift.\r\nDo not decide whether a report is filed — that decision belongs to your BSA/AML Compliance Officer." }