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Question & Answer

Question: I have just learned that a branch manager has been accepting cash deposits from a customer who says he is helping his mother by moving money from her "mattress" into the bank. He is trying to make her a better money manager. All of the cash deposits are about $9,500. This has been going on for months. Should I file an SAR?

Answer: Absolutely. This is classic structuring. And it also sounds like this customer tried a song and dance routine on the branch manager to get him or her to look the other way. Your branch manager should have known better. Surely by the third or fourth deposit, the pattern was emerging. So you should file an SAR on your branch manager as well.

Copyright © 1998 Compliance Action. Originally appeared in Compliance Action, Vol. 3, No. 18, 12/98




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