Skip to content
GeoDataVision
Learn More - Click Here!

New Reply Thread Options
#1209702 - 06/29/09 11:40 PM SAR Required?
Anonymous
Unregistered

A customer called a branch manager to ask if they had $20,000 cash on hand so they could withdraw funds from their account, which the customer said they needed for their mother to take on a trip overseas. The branch manager informed the customer they did not have $20,000 on hand, and referred the customer to a branch the next town over. While on the phone with the customer, the branch manager mentioned that a CTR would be needed. According to the branch manager, the customer seemed as if they were aware of CTR requirements but had not taken them into consideration, reportedly saying "oh yea - the $10,000 rule."

When the customer went to the branch the next town over, they withdrew only $9,900. During conversation, personnel asked the customer why they had changed the original amount, and the customer said they decided $20,000 in cash would be too much to bring overseas, so they would wire the rest.

Would you file a SAR on this activity?

Return to Top Reply Quote Quick Reply Quick Quote
#1209797 - 06/30/09 12:56 PM Re: SAR Required? Anonymous
MagicCity Offline

Power Poster
MagicCity
Joined: Apr 2003
Posts: 3,003
Fort Lauderdale, Florida
I don't think I would.
I think if the customer had said, when asked, "I forgot about the reporting etc.," - then I would file for sure.
But since he said that they decided that $20,000. was too much to take overseas, I would not file.

My reason being that in the first conversation it was the bank that brought up the reporting requirement, not the customer.

Return to Top Reply Quote Quick Reply Quick Quote
#1210116 - 06/30/09 04:56 PM Re: SAR Required? MagicCity
David Dickinson Offline
10K Club
David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
I agree. I would also monitor this account. If another large cash withdrawal occurs in a short time, you know they are structuring.
_________________________
David Dickinson
http://www.bankerscompliance.com

Return to Top Reply Quote Quick Reply Quick Quote
#1211005 - 07/01/09 09:32 PM Re: SAR Required? David Dickinson
WonderWoman Offline
Diamond Poster
WonderWoman
Joined: Mar 2007
Posts: 2,108
gone fishin'
I'm sorry - but I respectfully disagree. $9,900 is a huge red flag, especially after they were notifed of the requirements.

Their original intent was to withdraw over $10,000. If they had used the excuse "$20,000 is too much" along with a withdrawal for $3,000 or $5,000 or even $9,000 - I may be inclined to not file a SAR - but $9,900???

c'mon
_________________________
My opinions are my own, and not that of my employer.

Return to Top Reply Quote Quick Reply Quick Quote
#1211013 - 07/01/09 09:42 PM Re: SAR Required? WonderWoman
YoungAndEager Offline
100 Club
Joined: Apr 2009
Posts: 135
Indiana
I agree with newbsa.

Consider it this way, if they had physically come in to your branch and requested $20,000 cash (and you had it available) and you asked for ID etc to file CTR, then they 'changed their mind' to $9,900 would you file an SAR? I would.
_________________________
"...muffins are just bald cupcakes." -- Jim Gaffigan

Return to Top Reply Quote Quick Reply Quick Quote
#1211121 - 07/02/09 12:42 PM Re: SAR Required? YoungAndEager
Kelsey D Offline
Platinum Poster
Joined: Aug 2006
Posts: 516
Ohio
FWIW, I would as well.
_________________________
Don't make me say, "I told you so!" Sincerely, your friendly Compliance Officer.

Return to Top Reply Quote Quick Reply Quick Quote
#1211317 - 07/02/09 02:53 PM Re: SAR Required? Kelsey D
Anonymous
Unregistered

In my opinion, too much to take overseas means "If I take that much cash, I have to file a CMIR". In any event, it does appear the customer is trying to avoid reporting.

Return to Top Reply Quote Quick Reply Quick Quote
Quick Reply:
HTML is disabled
UBBCode is enabled




Moderator:  MagicCity, P*Q, Truffle Royale