Consumer Complaints and Assistance:
National Bank Anti-Fraud Resource Center Banker Information

Counterfeit Instruments

• To report counterfeit instruments drawn on your institution, please download the Counterfeit Reporting Form, which is a PDF document. Complete the form and either email it as an attachment to occalertresponses@occ.treas.gov or fax it to (202) 874-5214.
• To obtain an up-to-date listing of current counterfeit instruments, please click here (PDF). To view an individual alert, please see the full listing of alerts, which are viewable and downloadable in both Word and ASCII formats.
• Please note that the FDIC also issues Special Alerts regarding counterfeit instruments, which are available at their website.

Web-site spoofing is a method of creating fraudulent Web sites that look similar, if not identical, to an actual site, such as that of a bank. Customers are typically directed to these spoofed Web sites through phishing schemes or pharming techniques. Once at the spoofed Web site, the customers are enticed to enter information such as their Internet banking username and password, credit card information, or other information that could enable a criminal to use the customers' accounts to commit fraud or steal the customers' identities. Spoofing exposes a bank to strategic, operational, and reputational risks; jeopardizes the privacy of bank customers; and exposes banks and their customers to the risk of financial fraud.

Suspicious Activity Report Filing as Related to Advance Fee Fraud

Background

FINCEN has received inquiries regarding whether a financial institution subject to Bank Secrecy Act requirements should file a Suspicious Activity Report (SAR) on "4-1-9" or "advance fee fraud" schemes.

An advance fee fraud scheme typically begins when a person receives an unsolicited communication from someone in a foreign country, often Nigeria, who purports to be an official of the foreign government, bank or other substantial sounding organization. The solicitation will assert an urgent need for the recipient's help to transfer a large amount of money. Explanations regarding the money's source will vary and may include: proceeds from over-invoiced contracts or other contract fraud; disbursement of money from wills or estates; sale of crude oil at below market prices; unclaimed funds in deposit accounts, trusts, and security companies resulting from the untimely death of the account holder due to accident, execution or other cause of death; purchases of real estate; currency conversions; or winnings from an international lottery. The recipient is promised a portion of the money to be transferred, or a substantial commission.

These schemes have a common denominator-eventually the target of the scheme will be required to pay up-front (advance) fees (licensing fees, taxes, attorney fees, transaction fees, bribes, etc.) to receive the money or commission. Detailed information about these schemes is available from the United States Secret Service (USSS) website, the Internet Crime Complaint Center (IC3), the Metropolitan Police of London, and the Federal Trade Commission (FTC).

Financial Institution Guidance on Filing Suspicious Activity Reports

If a financial institution has not incurred a monetary loss from an advance fee fraud scheme and there are no other indicators of illegal activity warranting the filing of a SAR, it should not file a SAR and no further action is necessary.

However, if a financial institution has incurred a monetary loss or has identified other indicators of illegal activity, such as counterfeiting, forgery, or the misuse of an official U.S. Government seal, the financial institution should consider filing a SAR based on the requirements of 31 C.F.R. Part 103 and the SAR instructions. In addition, the financial institution should contact the local USSS or FBI field office, local police department, or other appropriate law enforcement agency. When the transaction causing the filing of a SAR occurs via the Internet or e-mail, it would be extremely helpful if the financial institution would also replicate the information in a complaint filing with the IC3.

In all cases involving a customer of the bank, whether loss is incurred or not, the bank should strongly recommend that the customer follow the guidance issued by the IC3, USSS, and FTC.

For general questions regarding SAR filing, financial institutions should contact their primary federal regulator or FinCEN's Regulatory Helpline at (800) 949-2732.

To download a SAR for filing, please visit FINCEN's BSA webpage. Additional information and a link to FINCEN is also available on our Suspicious Activity Report (SAR) Program webpage.