How do your employees respond when a customer brings in a DOJ letter they received, which tells them that they are suspected of structuring?

This is the first time I've seen one and a branch manager called me because a customer brought the letter in and was very confused. I told her to tell the customer that the letter didn't come from our bank. I was a little stumped, though.

Any suggestions? Obviously we can't tell them we filed a SAR on them.

Very interesting. The letter did not come from you and you know nothing about it. End of story.

"We don't know anything about the letter. If you are concerned, I suggest you talk with an attorney."

One suggestion I heard was, "the government knows everything." I just don't feel comfortable with that. I guess it's a last resort, but..

The IRS sends out "notification of law letters" that basically the say the same thing. The IRS also does "knock and talks" where they go visit the customer to discuss it personally. However, I've never heard of DOJ doing it. Since they have sworn off just confiscating customer funds for structuring in the absence of other criminal activity, maybe they have moved to a letter writing campaign?

In essence, your bank has been "outed" for filing the SAR as there is no one else who might possibly be familiar with your customer's cash activity.

Train your employees using this video, but get a copy of the letter and write to the author expressing any opinion you might have of the practice. Copy your Congressional representatives.

This is not a recent development. See Post 738340 in this thread from 2007.

Haha! Thanks.

It appears to be the same thing. Letterhead is Department of Justice, but the Notification of Law is on the bank.

I hadn't seen one of these letters until I came to this bank. My previous bank was tiny with very few SAR filings. We file many at this bank and apparently there have been several instances in the last few years of customers getting these letters. Some were extremely upset.

Just heard a DOJ representative reference the "knock and talk" visit (using that term). He also mentioned a "target letter" that is used when the individual continues to structure transactions after the "knock and talk."

The target letter asks the individual to meet with the DOJ and bring their lawyer to the meeting. After that meeting, the individual generally never structures transactions again...