Skip to content
BOL Conferences
Thread Options
#410306 - 08/18/05 07:32 PM SAR question
Anonymous
Unregistered

We had a regular customer come in the other day and ask to withdraw $9,000. He clearly stated that he didn't want to fill out all "that" paperwork and that's why he only want 9,000. The teller brough it to managment's attention anD we know this customer and researched the account and we don't believe this is necessarily suspicous (just a customer with a time constraint), but since he made that comment, must we file a SAR?

Return to Top
BSA/AML/CIP/OFAC Forum
#410307 - 08/18/05 07:43 PM Re: SAR question
Anonymous
Unregistered

My view is the customer intended to structure the transaction- File a SAR

Return to Top
#410308 - 08/18/05 08:17 PM Re: SAR question
Anonymous
Unregistered

Did he make additional cash withdrawals a few days before or after this transaction? Was he really structuring, or was he just complaining about the laws and regulations?

Return to Top
#410309 - 08/18/05 08:43 PM Re: SAR question
Kathleen O. Blanchard Offline

10K Club
Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
Structuring is just that...structuring the deposit/withdrawal to avoid the regulation. He structured and admitted it.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

Return to Top
#410310 - 08/19/05 02:41 AM Re: SAR question
Dolly Nugent Offline
Diamond Poster
Dolly Nugent
Joined: Nov 2000
Posts: 1,820
Southern California
This is going to sound harsh, but if you don't I believe you are being willfully blind to the situation. He admited he was trying to avoid the form. Protect yourself and the bank by filing a SAR. Next time, consider educating your customer. Perhaps he isn't aware that structuring is a criminal violation.
_________________________
Dolly Nugent
CRCM
Opinions expressed are my own.

Return to Top
#410311 - 08/19/05 10:43 AM Re: SAR question
Hussam Al-Abed Offline
Platinum Poster
Joined: Nov 2000
Posts: 551
Abu Dhabi / U.A.E
Quote:

This is going to sound harsh, but if you don't I believe you are being willfully blind to the situation. He admited he was trying to avoid the form. Protect yourself and the bank by filing a SAR. Next time, consider educating your customer. Perhaps he isn't aware that structuring is a criminal violation.




I second on that 100%

Return to Top
#410312 - 08/19/05 01:49 PM Re: SAR question
Skittles Offline
10K Club
Skittles
Joined: Sep 2002
Posts: 13,965
TN
Of course you can't tell them about SARs.
_________________________
My Opinions Only

Return to Top

Moderator:  Andy_Z