Skip to content
BOL Conferences
Thread Options
#1178421 - 05/07/09 07:34 PM SAR???
beegee Offline
Diamond Poster
Joined: Feb 2004
Posts: 1,110
South
Is this SAR reportable and if so for what reason:

We have a customer who has withdrawn roughly $150,000 over the last 8 weeks. His reason is "he was afraid the IRS was going to put a levy on his account again."

Thanks,
beegee

Return to Top
BSA/AML/CIP/OFAC Forum
#1178469 - 05/07/09 07:59 PM Re: SAR??? beegee
Skittles Online
10K Club
Skittles
Joined: Sep 2002
Posts: 13,965
TN
Did he take it out in cash?
_________________________
My Opinions Only

Return to Top
#1178475 - 05/07/09 08:02 PM Re: SAR??? Skittles
beegee Offline
Diamond Poster
Joined: Feb 2004
Posts: 1,110
South
He took a combination of cash and cashiers checks...

Return to Top
#1178482 - 05/07/09 08:07 PM Re: SAR??? beegee
Skittles Online
10K Club
Skittles
Joined: Sep 2002
Posts: 13,965
TN
It is up to your institution to decide whether or not to file a SAR, but I think you have a lot to review. FWIW - I would probably file, but I'm not in your shoes.
_________________________
My Opinions Only

Return to Top
#1178487 - 05/07/09 08:15 PM Re: SAR??? Skittles
beegee Offline
Diamond Poster
Joined: Feb 2004
Posts: 1,110
South
Thanks Duchess - what would be the reasoning; i.e. - what box to check, for filing?

Thanks,
beegee

Return to Top
#1178495 - 05/07/09 08:18 PM Re: SAR??? beegee
Skittles Online
10K Club
Skittles
Joined: Sep 2002
Posts: 13,965
TN
Did he try to avoid CTR filings? If so, you could use structuring. If not, possibly use 'Other' and define tax avoidance or something like that.
_________________________
My Opinions Only

Return to Top
#1178502 - 05/07/09 08:24 PM Re: SAR??? Skittles
beegee Offline
Diamond Poster
Joined: Feb 2004
Posts: 1,110
South
sounds good - thanks.

Return to Top
#1178510 - 05/07/09 08:29 PM Re: SAR??? beegee
BrendaC Offline
Power Poster
BrendaC
Joined: Sep 2001
Posts: 6,029
Sweet Home AL
I would probably call the local IRS CID office to report verbally as well so they can expedite their decision as to whether they need to pursue. Paying my taxes while someone else avoids paying theirs is one of my hot buttons.
_________________________
Life without Jesus is like an unsharpened pencil - it has no point.

Return to Top
#1178539 - 05/07/09 08:50 PM Re: SAR??? BrendaC
Skyline Offline
Platinum Poster
Skyline
Joined: Sep 2005
Posts: 590
Remember filing a SAR you have a safe harbor provision.
_________________________
CRCM, CLBB

Return to Top
#1178547 - 05/07/09 08:59 PM Re: SAR??? Skyline
EdieT Offline
Member
EdieT
Joined: May 2009
Posts: 76
PA
I would probably file. Unusual & suspicious to me.

Return to Top
#1179606 - 05/08/09 07:18 PM Re: SAR??? EdieT
Fallgirl Offline
Gold Star
Fallgirl
Joined: Mar 2005
Posts: 432
Wisconsin
I have a similar sitution. We have a customer that has had a tax levy placed on their account so they are cashing paychecks and buying money orders rather than deposit the money into their account (they're expecting another levy). I'm planning on filing a SAR.

Return to Top
#1179643 - 05/08/09 07:34 PM Re: SAR??? beegee
Elwood P. Dowd Offline
10K Club
Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
There isn't anything illegal about withdrawing or not depositing funds that might otherwise be subjected to levy. (If the customer sees the truck coming he's allowed to step out of the way. grin)

The IRS will appreciate your enthusiasm, but you should consider any related SAR filing as voluntary.

Return to Top
#1180374 - 05/11/09 04:13 PM Re: SAR??? Elwood P. Dowd
fnbgal Offline
100 Club
Joined: Mar 2006
Posts: 140
CA
Ken - thank you so much for your response. I was hoping that one of the experts would speak up and let me know that I'm not alone in my way of thinking.

Return to Top

Moderator:  Andy_Z