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#386078 - 07/14/05 08:49 PM Intent to avoid CTR
BSA4LIFE Offline
Gold Star
Joined: Nov 2003
Posts: 284
California
I would consider filing a SAR if a customer changed a transaction to avoid filing a CTR. But, if a customer just asks questions about what would or wouldn't require a CTR, would you file a SAR?

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#386079 - 07/14/05 09:16 PM Re: Intent to avoid CTR
devsfan Offline
Diamond Poster
Joined: Jun 2004
Posts: 1,927
NYC
Did he do any transactions after asking the questions? If he did and you consider them to be suspicious in light of the questions, I would consider filing a SAR. Either way, I suggest that you monitor his activity for a period of time.

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#386080 - 07/15/05 01:30 AM Re: Intent to avoid CTR
Dolly Nugent Offline
Diamond Poster
Dolly Nugent
Joined: Nov 2000
Posts: 1,820
Southern California
Remember, there are thresholds that have to be met for a transaction to be reportable. If there was no transaction that met the threshold, then you have no obligation to file a report. I agree with devsfan - monitor the account to see what happens next.
_________________________
Dolly Nugent
CRCM
Opinions expressed are my own.

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#386081 - 07/15/05 01:35 AM Re: Intent to avoid CTR
Fraudman CFCI Offline
Power Poster
Fraudman CFCI
Joined: Apr 2004
Posts: 3,189
Land of Steady Habits
If the customer first intends to transact more than $10K and then changes his/her mind when it becomes apparent a CTR will be filed, I ALWAYS file a SAR.

This is strutuiring to avoid, no question.

Will anything be done? Probably not unless there are other reports involving the same customer.

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#386082 - 07/15/05 09:04 PM Re: Intent to avoid CTR
BSA4LIFE Offline
Gold Star
Joined: Nov 2003
Posts: 284
California
This story gets better. Originally the customer asked at his home branch what the reporting threshold was and if check deposits would also trigger reporting. Then 2 days later he deposited a large check from a Title company, so I thought, OK that is why he was interested. Today I get a report from another branch that the same customer was in their office asking what the cash amount was for reporting and if he withdrew there, would his home branch know about it. I will definately be watching his account.

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