Like I said in my pevious post, "I know we have AML rules and KYC rules in the industry, and there are certain scenarios where we should be asking questions...".
Here is a scenario which actually happened. A person gives me $9,900 cash at a CIBC branch in Oakville; they live at College/Spadina in Toronto. They ask me to wire the funds to a bank in China using RBC as an intermediary.
So, this is a suspicious transaction for two reasons:
1) The person is aware of the FINTRAC reporting, as they are giving me $100 cash less than the amount that triggers a Large Cash Transaction Report that is sent to FINTRAC
2) The person is asking me to use RBC as an intermediary for their wire when that is not required; i.e. they are "layering" the transaction, which suggests Money Laundering
So in that instance, after the transaction is completed and the person has left, I am required to file a Suspicious Transaction Report which is sent to CIBC AML Division. I cannot do or say anything to tip the person off that I am filling out a Suspicious Transaction Report, as that would be illegal and I would be held criminally liable for my actions.
Here is another scenario that actually happened:
A client phones me to remove a hold. The client just opened the account. Her ATM limit is set at $300/day, with a cap of $900/week. The day is Thursday. Her account history looks like this.
Monday - $300 ATM Deposit
Monday - $300 ATM WD
End of Day Balance: $0
Tuesday - $300 ATM Deposit
Tuesday - $300 ATM WD
End of Day Balance: $0
Wednesday - $300 ATM Deposit
Wednesday - $300 ATM WD
End of Day Balance: $0
Thursday - $300 ATM Deposit
Balance: $300 Holds: $300
So, the client started with a zero dollar balance. She has been making ATM transactions all week. Her account balance is currently $300. The funds are on hold, as she has reached her ATM limit and needs a bank employee to manually remove the hold. I had a feeling the client was kiting, so I declined her hold request and referred the matter to her Branch Manager. Sure enough, all the ATM deposits were empty enevelopes. Once the account was adjusted, the account was closed and the bank incurred a $900 loss.