Who would go in front page of the SAR (Part II-Suspect information)?

Customer who has written series of seven checks totaling $50,000; checks were written out on same day.

Or

Non customer who cashed checks, one by one at four different branch locations, on three consecutive business days.

Thank you

It takes 2 to tango.

I agree with devsfan.

Do two suspect pages, one on the person that wrote the checks and the other suspect page on the person that cashed the checks.

I would want to hear my customer's explanation for writing several checks to same person on the same day. I have seen situations where contractors asked individuals to write different checks. The customers didn't understand why but accommodated the requests. In such a case, I would like the contractor as the suspect and document the customer's info in the narrative.

I would also contact the customer and inquire if there was a specific reason to issue X checks on the same day versus one. But with the non-customer bouncing from location to locaiton, I would say they are suspect #1. Now if the customer was assisting them by issuing these checks this way, and the non-customer cashed them in the manner described by the original poster, I would list them both as suspects.

I have seen Title companies issue more then one check to the same person on the same day at their customer's request. They typically would reference the same property address or similar in a way for them to tie the transactions together. If you have a reasonable beliefe that the customer was an innocent party, I would document that in my case notes as well in the event that an examiner selects that SAR case file for review.

If you can prove or reasonably suspect collusion, I would list them both, but if you have evidence to show that their customer requested these checks this way, then I would make sure to note that clearly in my notes and even in the SAR narrative.

Just a couple of thoughts.

I'm really not sure what talking to the customer is going to accomplish. What answer could they provide you, if in fact, you believe the transactions were structured to avoid currency transaction reporting?? Whether the customer knew what they were doing or not or whether they were just doing it at the request of the recipient of the checks, ignorance of the law does not make them innocent - they are a party to the transactions regardless.

If that customer has hit the radar for other questionable transactions, then maybe I would be more inclined to say suspect, but for just writing a couple of checks to the same person on the same day does not scream suspect to me unless they said they did it that way to avoid reporting for the payee, or assuming that they would be reported on the CTR as it came from their account even if they are not the conductor.

I have seen a lot of crazy stuff, but I just don't think I would automatically make them a suspect. But hey, that is just me.

I disagree. The customer may not have known that the contractor intended to cash the checks. They are party to the transactions, but not necessisarily to the introduction of currency into the transactions.

I guess I have a hard time believing in today's day and age that anyone cutting three sequentially numbers check for $9,900 on the same day does not know what they are doing. But regardless, at a minimum, the customer should be fully identified in the narrative, even if you do add a comment that you believe the customer was not in collusion.

I agree. Since the checks were drawn on your customer's account, he/she is going to included in the narrative of the SAR anyway. Just explain what happened and let law enforcement decide if one or both of the partners in the transactions are guilty.

OP - the person conducting transactions in currency is the suspected structurer. If you would file that your customer is a suspect because s/he wrote the checks in this manner, does than mean you would have filed a SAR on your customer even if none of the checks had been cashed? It's what the payee did with the checks that makes it suspected structuring. If the payee brought all seven checks into your bank and cashed them simultaneously - would you have filed a SAR, because seven checks were written instead of one? Not likely.