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#1037802 - 09/09/08 05:34 PM One time cash trans - SAR?
sammylou Offline
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Joined: May 2001
Posts: 186
the tundra
Retired railroad worker gets a $40,000 check from cashing out his mutual funds with our investment affiliate. Brings it to the teller and says he wants to cash the check, get $100 bills and open a safe deposit box. She tries to talk him out of all that cash and he says "I have my reasons; I want it in the safe deposit box." She tries again and he is unresponsive.

Not a customer who normally deals in cash. Certainly odd and is out of the ordinary for his regular activity. No attempt to structure the transaction, although we didn't disclose the CTR we had to file. Is this SAR reportable?

It's unusual but I can't say it's suspicious of any potential illegal purpose.... Thoughts?
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#1037815 - 09/09/08 05:43 PM Re: One time cash trans - SAR? sammylou
AnnRoy Offline
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AnnRoy
Joined: Jun 2002
Posts: 771
South
If he's the only authorized individual to access his box, perhaps he's hiding it from his spouse/signficant other/relatives.
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#1037827 - 09/09/08 05:53 PM Re: One time cash trans - SAR? AnnRoy
NewTooBSA Offline
Platinum Poster
Joined: Nov 2005
Posts: 568
Texas
I'm not sure I would report anything suspicious. Odd yes, suspicious no. You know the source of the funds and as been said on here numerous times, it is not illegal to keep cash in a safe deposit box.

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#1037854 - 09/09/08 06:10 PM Re: One time cash trans - SAR? NewTooBSA
sammylou Offline
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Joined: May 2001
Posts: 186
the tundra
Thank you.
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#1040675 - 09/11/08 10:01 PM Re: One time cash trans - SAR? sammylou
Compliance Mom Offline
Junior Member
Joined: Apr 2003
Posts: 45
Tennessee
I've said this before and was told my examiner is crazy, but we are being forced by the FDIC to file on any very large cash transaction that cannot be legitmately explained. I would assume with your customer's safe deposit box activity, if it were our customer, there would be no question. We'd file or hear about it next exam....

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#1040788 - 09/12/08 12:38 PM Re: One time cash trans - SAR? Compliance Mom
devsfan Offline
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Joined: Jun 2004
Posts: 1,927
NYC
Your examiner IS crazy.

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#1040965 - 09/12/08 02:46 PM Re: One time cash trans - SAR? devsfan
sammylou Offline
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Joined: May 2001
Posts: 186
the tundra
I agree on crazy. I haven't been criticized before on my "didn't file" decisions, so long as they were documented. We've decided not to file on this one and will just watch the account. Right now, odd yes, suspicious of illegal activity, no. That's where we're going with it. Thanks all for your input.
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#1042711 - 09/15/08 11:42 PM Re: One time cash trans - SAR? sammylou
BSA4LIFE Offline
Gold Star
Joined: Nov 2003
Posts: 284
California
We must also consider the banking situation right now. A lot of customers are afraid that banks are going to fail and they will lose their money so they are taking everything in cash.

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