Consumer complaint received 2023-06-20
Product: Money transfer, virtual currency, or money service — Virtual currency
Issue: Fraud or scam — 
Company: JPMORGAN CHASE & CO. (CA)

XX/XX/XXXX
This is my complaint against CHASE BANK. 
URGENCY: HIGH
IMPORTANCE: HIGH
[WITHOUT PREJUDICE]
I would like to draw your attention to XX/XX/XXXX - I had sent my complaint letter to CHASE BANK, in which I clearly stated
how this scam has affected me personally, psychologically andfinancially. 
I am afraid I have had to go through so much "bureaucracy" thus far in order to catch their attention to my concerns. This really doesn't
show their complaints department in a good light, to say the least; and certainly, does not contribute to my overall satisfaction and peace
of mind.
My complaint is against the bank that did not do its job properly (could not prevent/foreseen fraud and could not conduct a proper
investigation) and not against the vulnerable customer who fell victim and lost all the savings due to the misconduct of the bank.
I feel very distressed and cheated, all because no one took action immediately and practice their duty of care, therefore I only request what
I believe to be rightfully mine, as all institutions were more than negligent in protecting my account and handling the complaints. I 
comprehensively provided explanations and proof to my claim, even so, CHASE BANK never acknowledged my complaint,
therefore, I have approached you CFPB and I would like to receive your assistance on this matter.
General Obligation:
Commencing on or about XX/XX/XXXX, I fell victim to a multi-layered scam operation orchestrated by XXXX XXXX, XXXX XXXX, 
and XXXX XXXX (the Scammers), all of which aim at contributing to the goal of robbing and defrauding innocent people.
When determining whats reasonable and fair, we should focus on the issue of liability; common queries include, but are not limited to, 
the following (i) whether CHASE BANK did not take notice of any rule, law, or regulation, and/or possibly missed any material elements 
of the relevant bylaws or codes of conduct, that may have prevented them from protecting my financial safety; (ii) whether by virtue of 
CHASE BANKs custodianship over my funds or by its control over them, they owed a fiduciary duty to me and if so, whether that 
duty was breached; (iii) whether CHASE BANK promoted the transaction(s) in question despite being aware of the nature of the 
transaction(s) in question (iv) whether CHASE BANK was in compliance with its own policies and procedures; (v) whether CHASE 
BANK owed duties to myself, what the scope of those duties was, and whether CHASE BANK did not uphold those duties; (vi) whether 
CHASE BANKs conduct was unfair; and (vii) whether CHASE BANK has within its power the ability to, and should, compensate me 
for the harm that has befallen me.
Upon identification of such unusual or suspicious activity, it is crucial that the relevant staff member adequately describe the factors 
making an activity or transaction suspicious, thoroughly depict the extent and nature of this activity and properly communicate to the 
customer that such activity meets the relevant criteria of fraud.
In providing its services to a customer, a financial institution is required by law to exercise the care and skill of a diligent, prudent banker. 
In this case, this means that the payment service provider should not turn a blind eye to known facts pointing to a real possibility that 
their customer is being scammed. In other words, CHASE BANK must have had special knowledge of what was occurring or been alerted 
to a real possibility of fraud taking place. The financial institution must have known or reasonably ought to have known that I was dealing 
with a scammer.
Granted, there is room for diversity of view insofar as reasonableness is concerned. Indeed, there is a sense in which the standard of care 
of the reasonable person involves in its application a subjective element. 
However, it must be remembered that the correct test is always reasonable care in all circumstances, not average care. The fact that most 
people behave in a certain way may be good evidence that the conduct is reasonable, but this is not necessarily the case. Although 
reasonableness is a very fluid concept, all of the evidence suggests that CHASE BANK did not foresee the fraud and disregarded even the 
most obvious dangers in this respect. 
Situations do tend to repeat themselves and it is advisable to examine previous outcomes to see how the standard of the reasonable person 
should be applied, and that lessons can be learnt from the errors of the past.
Apropos of the fluidity of the concept of reasonableness, all CHASE BANK has done in this regard is set up a dichotomy of having or not 
having the legal obligation under consideration, however, that does not go one-inch toward explaining why various regulatory authorities, 
has maintained that financial institutions can, and should, protect consumers using their systems, advanced technologies, and rich 
experience.
SCAMMERS FRAUD SCHEME  ALLEGATIONS
On XX/XX/XXXX, I received a phone call in the morning at about XXXX XXXX. The caller identified himself as XXXX XXXX, ID ss(or XXXX) XXXX 
from XXXX. He stated that he was confirming a purchase that was made on my XXXX account of a gold XXXX that was to be delivered 
to an address in XXXX New York the next day on the XXXX. I told him that I had not made such a purchase and it needed to be cancelled. 
He said he would cancel it, but he needed to transfer me to their fraud division and asked me to hold for a moment. This was at XXXX XXXX.
The next person got on the line (XXXX XXXX), the same phone number. This person identified himself as XXXX XXXX BadgeXXXX XXXX 
U.S. Marshall. He proceeded to describe that my name was used to open several bank accounts, in Texas, New York, New Jersey, etc. rent 
a vehicle and that my name was being used in a money laundering scheme and possibly drug smuggling. He then started to tell me that he 
needed me to talk to one of their U.S. Marshals that were in that department and proceeded to transfer me to yet another person. He had 
me stay on the line and not hang up for the whole day. The next person got on the line but had a different phone number, 1-XXXX. 
He identified himself as a U.S. Marshall, XXXX XXXX, badgeXXXX XXXX, assigned to my caseXXXX XXXX, and that he would explain what 
we could do to protect my money and provide proof that I was not involved with committing any of the fraud. 
He said I needed to pull all my money out of my bank account and secure it so they could open a new account to put it into at my bank. 
He then said to stay on the line no matter what and to not tell anyone what we were doing and asked how much money needed to be 
secured, I then gave him my balance in my bank account. He never asked me for my actual bank account number. He then had me go to the 
bank and withdraw as much as I could in cash to take to a specific Bitcoin ATM that they provided to me after I let them know what city 
I was in. I used XXXX all day long because my car was in the shop.
I withdrew XXXX cash and proceeded to the Bitcoin ATM address they gave me. He kept stating that my XXXX trips would be refunded 
after all this was done. They sent me a QRC code to use at the Bitcoin ATM. I deposited the cash into the ATM and kept the receipt. Then 
he directed me to buy as many XXXX  cash cards as I could to secure the rest. I went to XXXX and was only able to purchase XXXX  cash 
cards for the amount of XXXX each. Then he asked if I could do an ATM cash withdrawal at XXXX for the rest. I was only able to 
withdraw XXXX because of limits.
I told him I was at all my withdrawal limits and could do no more for XXXX hrs.
He then said that once we got all my money secured that he would set up an appointment for the next day to meet another Marshall in 
person who would help me set up my new bank account and provide me with my new Social Security number and transfer all my money 
into the new account.
He said he would postpone his case for a day so we could continue the next day because if we did not secure my money, they would close 
my bank account and my Social Security number forever.
The next day, XX/XX/XXXX I was exhausted and didnt want to work with him anymore. I transferred my savings to checking for the next 
round of securing my money. I told him this and told him I did it because I needed to pay some bills with it and was leaving some money 
in my account,
He then got upset and said I broke the rules and hung up on me.
Please take notice that my funds were transferred through means of coercion and under false pretenses all along!
CHASE BANK is obliged to take some action if it is sufficiently aware of a real possibility that a fraud may be being perpetuated. If you 
don't question its customers instructions or raise the possibility of a scam with the customer in these circumstances, it may be liable if the 
red flags indicate the customer is:
 particularly vulnerable, or
 if the possibility of fraud was serious or real, not just suspected.
There are some recommendations to organisations for protecting customers from financial harm that might occur as a result of fraud or 
financial abuse; and gives guidance on how to recognise customers who might be at risk, how to assess the potential risks to the individual 
and how to take the necessary actions to prevent or minimise financial harm.
These recommendations are established as a general principle, the organisation should deliver a service that:
1) Takes a proactive approach to minimising risks, impact and incidences of financial harm and it sets out systems and tools for 
the prevention and detection of fraud and financial abuse. As a general point, it says organisations should ensure that all systems are 
developed using technologies and methodologies that are effective in the prevention of fraud and financial abuse, through authorised 
and unauthorised payments, thereby minimising the risk of financial harm to customers. As regards to the detection of fraud and 
financial abuse, it says the organisation:
A) should have measures in place across all payment channels and products to detect suspicious transactions or activities that 
might indicate fraud or financial abuse. It then lists the following examples of suspicious activity on customer accounts:
a. multiple cheque books;
b. sudden increased spending;
c. transfers to other accounts;
d. multiple password attempts;
e. logins from new devices, multiple geographical locations;
f. sudden changes to the operation of the account; Unusual transactions are transactions whose amount, 
characteristics and frequency bear no relation to the economic activity of the customer, exceed normal market 
parameters or have no apparent legal justification. 
g. a withdrawal or payment for a large amount;
h. a payment or series of payments to a new payee;
i. financial activity that matches a known method of fraud or financial abuse.
B) organisations should have a process in place to ensure that staff make contact with the customer to verify the financial 
activity, challenge its authenticity, explain the nature of the suspected or detected fraud and discuss an appropriate plan of action.
I am deeply convinced that the disastrous results that I have previously elaborated upon will continue to ensue if no responsibility is 
adopted by CHASE BANK in relation to this matter. I have also thoroughly detailed why they cannot simply dismiss this problem by 
strictly adhering to legal technicalities which, after careful reflection, struck me as being nothing more than self-interest. Indeed, it seems 
to me utterly unfair to disregard fragile, sensitive, and vulnerable consumers who are afflicted by such allegedly malevolent acts, thereby 
keeping an unjust status-quo that is corrupting our society at its core.
Conclusion:
Based on my analysis, and as confirmed by various authorities concerned with such matters, there is abundant evidence that forward thinking financial institutions ought to take reasonable steps to forestall fraud, or at least mitigate its risk by using an effective risk 
management system, demonstrating their undisputed ability to responsibly and pre-emptively respond to questionable transactions in the 
digital arena. The use of such systems, largely based on newly adopted technologies aimed at effectively navigating the evolving threat
landscape, is only one of a number of possible endeavours undertaken in this connection, alongside the application of past knowledge and 
experience related to popular fraudulent practices.
CHASE BANKs non-observance of the fundamental principles of justice  that is, to completely overlook and not even remotely try to 
mitigate the suffering of vulnerable consumers is inexcusable given the size of the establishment and the vast resources at its disposal as 
the direct result of the patronage of clients like myself. 
In summary, I respectively ask your organisation to consider my points, given your personal and companywide obligation to provide a fair 
and reasonable investigation into the complaint.
I look forward to your input and would gladly cooperate to reach a fair and reasonable outcome.
Thank you.
XXXX XXXX

Page 1 of 7 XX/XX/XXXX 
XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX, NY
Re: Demand Letter 
 For negotiation purposes only, without effect as to any and all rights
Attn: Claims/Fraud Dept.
Dear Sir/Madam, 
The goal of this letter is twofold: first, it aims to establish that a duty of care was breached, inasmuch as 
you have failed to perform adequate due diligence or/and have not acted in a reasonable and prudent 
manner to prevent foreseeable substantial damages I suffered as a result of a fraud [1]. Second, it shall 
serve as a formal written demand for reimbursement based on the aforementioned grounds, among 
others.
A very comprehensive analysis of fraud prevention suggests that by processing an atypical, non-routine 
transaction(s), and/or by being aware of other fraudulent schemes similar to the one alleged herein 
and/or ignorance of obvious warning signs of fraud, you engaged in/ is a pattern or a practice of wrongful 
and negligent conduct which provided substantial assistance to advance the commission of a fraud that 
resulted in my financial and psychological damages. The facts and details concerning the actions in 
question are set forth hereunder.
OVERVIEW
 Commencing on or about XX/XX/XXXX, I fell victim to a multilayered scam operation
orchestrated by XXXX XXXX, XXXX XXXX, and XXXX XXXX (the Scammers), all of which aim 
at contributing to the goal of robbing and defrauding innocent people.
 Money was transferred from my account via debit card, and through an intermediary named
Bitcoin Of America in the total amount of XXXX XXXX USD utilizing your services.
 This letter shall thrust into the spotlight, inter alia, the increasingly important role financial
institutions play in the fight against financial crime and fraud, and the pressing need for higher
levels of supervision and vigilance within your organization.
 Additionally, it is vital that you will immediately take all actions within your power to remedy the
situation, whether by raising chargeback in respect of the transaction in question or reimbursing
me and crediting my account, for the full amount of these payments, in the total amount of XXXX XXXX USD
 Heres an indisputable fact: had you looked at the wider circumstances surrounding the abovereferenced transaction, this illicit transfer of wealth could have been prevented.
 Executing transactions without proper authority is not only a severe regulatory offense but also
an irresponsible and reckless disregard for the customers financial safety.
1 FCA: A more effective approach to combatting financial crime (XX/XX/XXXX)
Page 2 of 7 XX/XX/XXXX 
2 
 Against this background, and without derogating any of my rights, I hereby hold you liable for
financial and emotional harm as well as medical problems relating to this victimization and
demand that you reimburse my account in full within 10 days from the date of this letter.
INTRODUCTION
Financial crimes and fraud investigations often involve a high degree of sophistication, complexity, and 
sensitivity to detail. Accordingly, this letter aims to address the issue at hand as profoundly and fairly as 
possible, by taking into consideration contextual regulations, laws, and bylaws, as well as guidance, 
standards, and rules promoted by supervisory authorities, relevant codes of practice and (where 
suitable) what was good industry practice (GIP) at all times relevant hereto. The allegations contained 
herein are predicated either upon knowledge with respect to myself and my own experience or upon 
facts obtained through investigations conducted by qualified third parties. I strongly believe that 
substantive evidence in support of the allegations set forth herein will be found after an appropriate 
opportunity for discovery. Key facts supporting the allegations contained herein are known only to the 
Scammer or/and are exclusively within their control.
I did not know, and through the exercise of reasonable diligence could not have discovered, the 
fraud that was being perpetrated upon myself by the Scammer. Fraud is commonly conceptualized 
as withholding from the weaker party in a financial transaction information which is necessary to make 
an informed, rational or autonomous decision.
In this regard, even access to adequate information is insufficient to achieve complete autonomy. A 
complication here is that the weaker party might have trouble analyzing the data at hand sufficiently well 
to identify fraudulent schemes. A reasonable solution is that financial institutions would be required 
to promote transparent communication in which they track the understanding of its customers. 
The false representations and omissions made by the Scammer have a tendency or capacity to deceive 
victims, such as myself, into unwittingly providing funds that fueled the Scammers fraudulent scheme 
and therefore are, by their very nature immoral, unethical, oppressive, unscrupulous, and substantially 
injurious to consumersall at once.
As a result of the Scammers deceptive practices, I was deceived into transferring my funds to them. The 
false statements of material facts and omissions as described above; and the sham transaction(s) the 
Scammer perpetrated upon myself; were unfair, unconscionable, and deceptive practices perpetrated on 
me which would have likely tricked a reasonable person under the circumstances.