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Question & Answer
Question: Our customer has a legitimate business, however it happens to be on the other side of the border-out of the United States. He has such bargains that people from the U.S. go over the border frequently to buy in his store. His deposits are in keeping with the volume of his business, in the form of checks and cash.
He replenishes his inventory in the other country also. So two or three times a month he comes in and withdraws $9,000 in cash to buy inventory. He told us he keeps it to $9,000 so he doesn't have to fill out a CMIR at the border.
He and the money are all legitimate. Do we have to fill out an SAR on him?
Answer: Yes! Look at just the facts in the case. Whether or not the business is legitimate really makes no difference. He is structuring,(and told you so!) and structuring is a violation that must be reported. Your examiner will be looking for the SAR if the structured withdrawals are discovered. Always cover yourself to the conservative side where examiners are involved. Our advisor says, "File", even though the authorities probably won't be interested.
Copyright © 1997 Bankers' Hotline. Originally appeared in Bankers' Hotline, Vol. 7, No. 2, 1/97
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