In the old American paper check system there was an important but subtle distinction between "fraud in the making" and "fraud in the inducement". If a criminal stole your checkbook and forged a check then an intermediary (like a bank or a grocery store) which cashed a stolen check could be on the hook for the money--if you protested to your bank the transaction could be reversed. However if the criminal simply induced you to write them a valid check (e.g. as payment for a non-existent bicycle) then any intermediary that cashed the check is not on the hook, and the only recourse is to get the money back from the criminal.