An applicant provides identity documents that appear altered, then abruptly withdraws the application when asked for verification. The loan officer suspects fraud. What is the most appropriate first step under the company's AML program?

Explanation

Under an AML program, employees who detect suspicious activity should escalate the concern through internal channels (such as the designated compliance officer) so the company can evaluate whether a SAR must be filed with FinCEN. Loan originators are typically not the ones who file directly, but they must recognize and report red flags. Confronting third parties or ignoring the issue is improper.