04/14/2024
If using a software program, we become aware of a check drawn on our customers account is for sale on Telegram (a marketplace for help depositing a stolen checks) and it is over $25k would a SAR be required? We froze the item and to our knowledge the check was not purchased or negotiated.
01/21/2024
I have a CTR question I have yet to see posted anywhere. Any cash
transaction(s) more than 10K to a joint account by any conductor is a CTR. However, what if there are multiple (3) joint accounts. EX: $5,000 cash deposit by Suzy to account A; $5,000 cash deposit by Suzy to account B; $1,000 cash deposit by John Doe to account C. All 3 accounts are jointly held by the conductors. Would this be considered a CTR because Suzy and John can benefit from the $11K, via separate accounts or exempt because not more than one person conducted to a single (one) joint account?
09/17/2023
I am looking for guidance on what information to include on subsequent filings of a Marijuana Limited SAR. I followed the guidelines on Fin-2014-G001 for the initial SAR - and now have a 90 day coming due. I'm looking for any suggestions or documentation?
03/26/2023
A dispensary (Marijuana Related Business) just opened this month in town. We have two members (we are a credit union) that receive payroll from there (ACH).
- Given their employer, is it illegal for them to bank with us?
- Do we need to terminate our relationship with them?
Our policy only states for MRB's that we would allow tier 2 and 3. Technically it is an individual, not a business though. Are we allowed to keep them? I know there are SARs we may have to file for MRB's (limited/terminated, etc.).
If we keep thee depositors, do we have to file a SAR every 90 days on the individuals as long as they are employed at the dispensary?
We understand there is a certain risk having them. There is really no guidance from FinCEN regarding employees of MRB's, just MRB's themselves. Any guidance would be greatly appreciated.
03/19/2023
When filing SARs, for the total amount of reported activity would you include both incoming and outgoing transactions when it's the same funds?
Example: Customer received an unusual wire for $50,000 and withdrew the funds in a structured manner. Would the total amount reported be $50,000 or $100,000?
10/09/2022
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.
03/20/2022
If we have a FinCEN 314(a) match, besides reporting it on the SISS website,must we file a SAR?
01/09/2022
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?
11/14/2021
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.
11/14/2021
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?