An elderly customer has been withdrawing cash from time to time, followed by a visit to her safe deposit box. She recently told a teller that she is taking money out of her account so the government would not get it when she goes into the nursing home, and then said that she was placing the money into her box. Opinions on whether this is SAR-reportable for hiding or secreting funds?

If it passes the thresholds, it's fraud. I've seen a couple of cases where it was prosecuted.

As a former BSA Officer I had a manager who told me once the fraud was not committed until the signed Medicaid paperwork was submitted with the required information on withdrawals during the lookback period omitted. That being said, since she told you her purpose was fraudulent, I would probably file if it met threshold.

That is definitely considered a red flag. I do not know how much cash she is taking out, but if you know she is keeping the withdrawals under the reporting requirements, that is structuring and requires a SAR. She has also made a statement as to what she is doing with the funds which if you decide to do a SAR should include her explanation.

Thanks for the input!