Suspicious ATM Activity
Question: We had over $10,000 in cash deposited into our ATM in numerous envelopes, one right after the other, with the same card number. Part of the funds were deposited Sunday morning and the balance just after midnight on Monday, so it gives the appearance of structuring. The envelopes were ours, but the customer and the account number are for another financial institution. Are we required to complete a Currency Transaction Report (CTR)? And if so, how do we go about it? We haven't contacted the account holder's bank because we didn't know what they could tell us with all the new privacy laws. We have no identification to put on the CTR. The account holder's bank is only three blocks away, and they have an ATM, but their ATM does not accept deposits.
Answer: I would first try and contact the bank that has the account. If you talk to their Bank Secrecy Act staff, I am sure they will understand the predicament you're in. Hopefully, they will cooperate enough to permit you to fill out at least some information on the CTR.
Second, you should seriously consider filing a Suspicious Activity Report (SAR) on this transaction (factors: very large cash deposit, no identifying information supplied by the depositor; a series of six or seven deposits at once, attempted structuring, large denomination bills that are inconsistent with deposits from retail accountholders, etc.). It may be that the other bank can provide you with an "innocent" explanation for this transaction. However, I think your guard should be up. I'm sure your examiner, on review, might want you to file.
Note from the editor: Our thanks to Peter Djinis for his help with this problem. And I wanted to pass on the information that BANKERS' HOTLINE has found FinCEN to be extremely cooperative and available for questions such as these. Our thanks to them also for their input. And for those of you that want "the rest of the story" - the other financial institution did supply the information necessary, and the Security/BSA officer filed both a CTR and an SAR.
Copyright © 2005 Bankers' Hotline. Originally appeared in Bankers' Hotline, Vol. 15, No. 7, 7/05
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