I am on the fence with a SAR referral. We have a 21 year old college athlete who deposited approx. $12,000 in cash to her account. Clarification: my bank is in a high volume cash area (also a HIFCA). I am so used to seeing hundreds of thousands of dollars in cash that this seems like little or nothing. Other transactions on the account include cashing (depositing the checks and then withdrawing cash) of two third-party federal student loan checks. When questioned about the cash deposited, she said it was her savings. She also exchanged $1,000 in twenties for one hundred dollar bills. My initial response was to file as the activity was unusual, but after thinking about it I think we should monitor the account for another 30-90 days. My sticking point is whether or not I believe she committed a crime. I could use a sounding board so please let me know your opinions. Thanks!

We would monitor it for another month or 2.

No explanation for the currency exchange?

<>

Just playing devil's advocate:
Do you have to know that she's committed a crime before you file a SAR? No. It is suspicious.
You have a 21 year old student that exchanged about $1,000 worth of $20's to $100's. Weird.
The same student deposited $12,000.00 cash? And withdraws cash?
Does she have a job where she would earn cash like computer work or, I don't know, a stripper?

I would probably file the SAR because it is suspicious. I remember Ken saying in one of his seminars (which are excellent by the way!) that it isn't a Known Crime Report but a suspicious activity report. Maybe get more info on her but I would file it. But that's just me.

Thanks for the input. On the exchange no additional information. On the crime question my perspective was that her explanation was not unreasonable. When I looked over the account history the transaction stood out. The previous balance was $2.04 and the balance 90 days ago was around $1,200. But I also figured that if she were involved in illegal activity she wouldn't have deposited a reportable amount.

We have had one or two students do this. In our situations it was money from a relative for school expenses. Now the relatives is probably dealing in cash and is suspect but they were not my customer. The student didn't structure and we watched the account and saw the $ was used for tuition, fees, etc. We did not report it. (We did not have a currency exchange, however.)

Had the student done something unusual with the funds, or continued to make large cash deposits we would have made a different decision.

I am with Amy on this one.

I err on the side of filing. It is an unusual transaction for this customer, you received an explanation of the source of the funds, but is it believeable...then there was the bill exchange. I have filed SARs on situations similar to this...not defensive filings, just interpreting the BSA very conservatively...the Examiner telling me 2 years ago that we "did not file enough SARs" may be why I always err on the side of filing...but as I always say, I would much rather explain why I did file a SAR rather than trying to explain why I did not file a SAR.