Am I encouraging a customer to structure if I make them run cash as a deposit into their account ,and then debit their account for a cashiers check instead of letting them just purchase a cashiers check with cash?
I like to have a paper trail and proof that the purchaser is a customer, that is why I run it through an account first.
If we have a FinCEN 314(a) match, besides reporting it on the SISS website,must we file a SAR?
If a cash intensive business has a private ATM which they service themselves and they do not have any cash withdrawals from their account, would that in itself be SAR worthy?
FIN-2021-A002 and FIN-2020-A007 describe Unemployment and Economic Impact Payment Fraud that financial institutions should be aware of. However, the economic payment amounts and most unemployment insurance amounts are below SAR reporting thresholds. Is there a requirement to look for and file a SAR for these types of fraud even if the amount is below the SAR reporting threshold?
We have a CTR dilemma. A customer came in with $20,000 cash.
- The funds were first deposited into his account.
- He then wanted to purchase a cashier check for $7,000.
- He returned later the same day with an account number of a family member and wanted to transfer $18,000 using the cash deposit and preexisting funds from his account. He is not on the family member's account.
The reason stated was that they are in the process of buying a house and escrow wanted him to show the proof of funds in a statement which was the reason for the transfer. How would you complete the CTR in this situation: is there only one Part 1 (customer) or two Part 1 (customer and family member)? And the $7,000, would be under negotiable instrument and $13,000 under fund transfer?
We also plan on filing a SAR.
I have a customer that appears to be processing personal transactions through his business account with FanDuel internet gambling site. FanDuel operates under a specific exemption written into the Unlawful Internet Gambling Enforcement Act of 2006 (UIGEA) that allows for fantasy sports contests. Am I correct in thinking that the use of FanDuel is not a violation of Reg GG? Also, is conducting personal transactions through a business account SARable?
We filed a SAR for possible structuring. After the 90 days we found there to be no other cash transactions. Now it has been eight months and we suspect this same customer for structuring again. Do we file a new SAR or recurring from the one we previously filed eight months prior?
Filing Institution Note to FinCEN in SAR form -- I'm aware there is a 50 character limit, but is there any indication that we
should only be entering one advisory at a time or are multiple entries allowed if they all fit?
We have a customer who is a young and receives a very small paycheck. It looks like some really big deductions are held by the employer. Is this normal?
Why does our financial institution no allow people to deposit cash into another person’s account?