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#1226081 - 08/01/09 04:47 PM 82 year old takes out a lot of cash
Tryin-2-Comply Offline
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Joined: Apr 2003
Posts: 202
Hills of TN
Here's the sitaution.
82 year old comes into the bank - withdraws $70,000 - stated she was "doing a driveway" -

concerns:
fearful this is a con
cash is unusual for an 82 year old to have
SAR filing - becuase its unusual and doesn't make business or (in this case individual) sense - i feel the need to file.


Any thoughts?

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#1226086 - 08/01/09 09:04 PM Re: 82 year old takes out a lot of cash Tryin-2-Comply
MagicCity Offline

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MagicCity
Joined: Apr 2003
Posts: 3,003
Fort Lauderdale, Florida
We are seeing quite a few elderly people not trusting banks and wanting to take out large amounts of cash, although not that much cash.
I would be concerned about a scam.
Did anyone talk to the elderly person and ask about it?
We would have had a bank officer talk to the elderly person and ask questions as to whether they were being intimidated etc.
In Florida we have strong laws against elderly abuse and we can call an agent if we believe that a family member may be intimidating the elderly relative.
If you have done that, I don't know that it goes to the level of a SAR filing.
But, if you feel that is the only way to bring it to the authorities attention you can file and add as Other in the SAR that you are concerned that it may be a crime against an elderly person.

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#1226091 - 08/02/09 02:09 PM Re: 82 year old takes out a lot of cash Tryin-2-Comply
Elwood P. Dowd Offline
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Joined: Aug 2001
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Next to Harvey
You have plenty of time to figure out whether or not to file a SAR. Your priority is to figure out what responsibility your bank may have to contact a state agency or even local law enforcement regarding potential financial abuse of the elderly.

You may be required. You may be allowed. Either way, you need to do something to try to help prevent the fraud. Teller training should have mandated that a teller would bring any comparable situation to the attention of a supervisor before it took place.
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#1231212 - 08/11/09 08:47 PM Re: 82 year old takes out a lot of cash Elwood P. Dowd
ShawnMosch Offline
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ShawnMosch
Joined: Feb 2003
Posts: 27
I agree with MagicCity that this person could be a scam victim. Many times these are the victims of the scams where they believe they are helping someone get money out of the country and will be getting millions back in return.

Shawn Mosch
Co-Founder of Scam Victims United

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#1231442 - 08/12/09 02:25 PM Re: 82 year old takes out a lot of cash ShawnMosch
Tryin-2-Comply Offline
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Hills of TN
If the officer speaks with the customer and they insist that they want their money becuase of the economy - what are you doing? We are documenting the file - what was discussed and not filing a SAR. But what about the 82 year old customer who takes out $100,000 over a 4 week period in increments of $25,000. We know its because of the economy and that's what they've told us. but is is suspicious. IMHO - no. they just want their cash -

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#1231836 - 08/12/09 09:40 PM Re: 82 year old takes out a lot of cash Tryin-2-Comply
compliancemom Offline
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Joined: Mar 2009
Posts: 22
West TN
I've also experienced several incidents like this where huge amounts of cash were withdrawn for the same stated reason. There's alot of money stuffed under mattresses and buried in fruit jars right now. Nothing suspicious about it, however, we have been instructed by our regulator that this is definitely unusual enough to file a SAR on.
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#1232176 - 08/13/09 04:27 PM Re: 82 year old takes out a lot of cash compliancemom
John Burnett Offline
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John Burnett
Joined: Oct 2000
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Cape Cod
Do you remember the large withdrawals in 1999 with the threat of a Y2K meltdown looming large?
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#1232419 - 08/13/09 07:57 PM Re: 82 year old takes out a lot of cash John Burnett
chatty Offline
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Posts: 34
I am aware of reporting to state agencies, but what about suspected exploitation of the elderly by a family member which aggregates to over $5000 over a period of time? Is that SAR reportable?

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#1232566 - 08/13/09 10:02 PM Re: 82 year old takes out a lot of cash chatty
Tryin-2-Comply Offline
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Hills of TN
yes, I do remember the 1999 issues - but, BSA / AML regulators weren't as "ruthless" as they are today.

So, here's a new one: Customer takes out $172,000 over a short period of time. The branch insisted that the customer not withdraw the money, but becuase of the economy - the customer would not hear of it. The branch told the customer they would not be responsible for giving them that much cash - so the branch broke it up into $25,000 increments over several weeks. Everyone at the branch tried to talk the customer out of this - so, would you file a SAR? It's documented as to what happened, the branch tried to keep the customer from taking that much cash. What would you do?

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#1232909 - 08/14/09 03:40 PM Re: 82 year old takes out a lot of cash Tryin-2-Comply
fnbgal Offline
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Posts: 140
CA
If the source of funds were good and the customer was a long-time, well-known customer, I would not file a SAR (as long as there were no other red flags). I would document everything you know and leave at that.

Of course, I've been told that I don't have suspicious bone in my body...I actually just think that customers are entitled to get cash if they want without a SAR being filed on them.

We have seen a fair amount of cash taken out because of the economy situation. We also have a lot of customers tell us they're taking cash because either their other bank will put a hold on their check, including cashier's checks, or they're buying something and the seller will only take cash. It doesn't help that you can't trust cashier's checks anymore.

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#1233140 - 08/14/09 06:37 PM Re: 82 year old takes out a lot of cash fnbgal
Tryin-2-Comply Offline
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Joined: Apr 2003
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Hills of TN
I hear you - it's just hard to determine -

final decision: long term customer, scared of economy, source of funds known. NO SAR.

Thanks to all for input.

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#1233253 - 08/14/09 08:31 PM Re: 82 year old takes out a lot of cash chatty
chatty Offline
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Joined: Feb 2006
Posts: 34
Originally Posted By: chatty
I am aware of reporting to state agencies, but what about suspected exploitation of the elderly by a family member which aggregates to over $5000 over a period of time? Is that SAR reportable?


This probably should have been a new post - but can someone help me out on it?
Thanks

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