have a customer who withdrew 90,000 cash around November 2008. A CTR was filed at that time. Apparently customer stated something about fears reagrading the Pres election.

Same customer has recently made two 10,000 cash deposits about sixteeen days apart. Struggling over whether to file a SAR. If I see one more I will file for sure but at this point I am unsure if I should.

I think your thought process is correct.

I would wait for the third one.

I agree with MagicCity.

Chances are that customer went home and the $90,000 ended up under the mattress or a closet safe. I'm not that concerned because of the length of time between these two transactions - 16 days. Chances are he/she is "unintentionally" structuring. He/she is probably slowly trickling the money back into the bank. Those fears might still be there, so putting the full $90,000 back right now, is probably out of the question.

I'd definitely wait until the 3rd one.

When we aggregate cash for SARS we use as one criteria 2 or more CTR's within 1 year. Also, if they aggregate on the over 3,000 report more than 10,000 then their account is looked at for the past year for all transactions and a possible reason for cash coming in.

You don't have to have a particular reason to fill out a SAR. If you are suspicious, there is nothing wrong with you filling one out but in your situation, I would.