The Elder Member and the Suspicious Wire
A 78-year-old member, Ms. Okonkwo, has banked at the credit union for 31 years. She arrives with a younger man who identifies himself as her 'nephew.' She asks to wire $48,000 - nearly her entire share account balance - to a newly opened account at another institution. The teller notices she seems confused about the recipient's name and the purpose. The 'nephew' answers most questions. The credit union's wire policy requires member-initiated requests and a callback verification for wires over $10,000. Ms. Okonkwo has no documented power of attorney or joint account holder. The credit union suspects elder financial exploitation but has no proof. The man becomes agitated when asked to step aside.
1. What should the credit union do in the next 30 minutes, and what legal and policy hooks apply?
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This is a textbook suspected elder financial exploitation scenario. Immediate steps: (1) Do not process the wire yet; invoke the callback verification requirement - call Ms. Okonkwo at her number of record, privately, without the man present. (2) Separate the member from the companion for a private conversation if possible. (3) Document everything: who said what, the man's identity, the recipient account, the member's apparent confusion. (4) If the member cannot confirm the wire independently, decline to process it and offer to hold it pending family or adult protective services involvement. Legal hooks: many states have elder exploitation reporting statutes that permit or require reporting to Adult Protective Services; the credit union's BSA/AML program and FinCEN guidance on elder exploitation support filing a Suspicious Activity Report. The wire policy's callback requirement is the credit union's own control - use it. Do not accuse the man; stay professional and protect the member.
2. Should the credit union file a SAR, and what are the timing and confidentiality constraints?
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File a SAR if the credit union knows, suspects, or has reason to suspect the transaction involves elder financial exploitation or is designed to evade BSA requirements. FinCEN guidance treats elder exploitation as a reportable suspicious activity. Timing: file within 30 calendar days of initial detection; if no suspect is identified, up to 60 days. Confidentiality: SARs are confidential - do not tell the member, the nephew, or anyone outside authorized personnel. Do not tip off the subject. Content: describe the pattern, the member's vulnerability, the companion's role, and the amounts. Keep the SAR narrative factual. Also: consider whether the credit union should place a temporary hold or require in-person verification for future large transactions from this account, consistent with its account agreement and applicable law. The SAR does not stop the wire by itself - the credit union must also act operationally to protect the member.