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Question & Answer
Question: We have a husband/wife book sales team who have a business account and a joint personal account with us. They've been our customers for a little over three years. They are on the road, selling, for three weeks out of four. During the week they're home, they come into the bank and deposit between $5,000 and $8,000 in cash into their business account. Just before they go "on the road" again, they come in and get $1,000 in small bills and change to take with them. We've become very aware with our Bank Secrecy Act training of filing on suspicious transactions. Do we need to file on these customers' large cash deposits?
Answer: Our conversation determined some important facts about your customers. First, we asked, "Do you suspect your customer of money laundering?" The answer came back immediately, "Oh, my! No!-We've known these people a long time. They're local and long time residents here in town."
Further discussion brought out the fact that the account has always been run this way. And that the customers were personally known to several of the tellers and customer service people.
The answer to whether this is a suspicious transaction was answered by the above information. No filing is necessary on the activity on the account. It might become suspicious if the amounts changed drastically, or if habits changed-for instance, if they didn't go "on the road" and still brought in the same amount of cash.
We've become perhaps just a touch paranoid about filing on suspicious transactions. A good, common-sense evaluation will usually supply you with the correct answer about whether or not you should file.
Copyright © 1994 Bankers' Hotline. Originally appeared in Bankers' Hotline, Vol. 5, No. 1, 8/94
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