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SAR - All the Deposit Details?
Answer by John Burnett, BOL Guru
Guru Bios
Question: We have a customer who continually structures his deposits to keep from exceeding the $10,000 threshold. This has been going on for about 3 years, and I have been submitting SARs every 90 days. Our examiners say that I need to give details listing each deposit from the beginning. This is 2 to 3 deposits a day for 36 months. On the SAR form, I only state that there are deposits made on a daily basis totaling $10,000 per. I also state how much this is monthly, in dollars, and how many days each month it occurs. I also state how much this totals to date. Do I really need to give all of the details of each deposit? This will total over 1,200 deposits.
Answer: The examiner seems to believe that law enforcement would better be able to look at your SARs to determine whether to start an investigation if they had more detailed information. It's hard to disagree with that logic, although a list of dates with the number of cash deposits each date and the total cash deposited might provide the same level of information. As you were submitting your question, I do hope you thought to wonder, "Why do we still bank this customer, if it is so onerous to file these SARs every 90 days?"
First published on BankersOnline.com 5/12/08
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