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#1239318 - 08/26/09 02:35 PM SAR Reportable Transaction
CrashDavis Offline
Gold Star
Joined: Jun 2005
Posts: 283
We had a customer come to one of our locations and withdrew cash in the amount of $20,000.00. A CTR was filed as required. In review of account activity this was the only large withdrawal on this individual over the past 4 months. He was president of a roofing company and is now retired. He has his social security check being deposited monthly. Keeps a large balance in account, around $70,000.

My question is should a SAR be filed on the $20,000 withdrawal even though a CTR was filed and no structuring was ocurring.

Thanks for your help.

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#1239407 - 08/26/09 03:09 PM Re: SAR Reportable Transaction CrashDavis
Deena Offline
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Deena
Joined: Nov 2000
Posts: 2,701
PA
You should only file a SAR if you think the transaction was suspicious. Determining that may require further investigation and/or a discussion with your customer.
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#1239417 - 08/26/09 03:15 PM Re: SAR Reportable Transaction CrashDavis
Miss Banker Offline
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Joined: Feb 2004
Posts: 235
In situations such as this, it is really hard to say whether you should file or not. Some banks file because the transaction is out of the norm or established pattern of the customer; we do not file solely based on this factor. Unless I had some background knowledge or facts to support my filing or a gut instinct that told me it was suspicious, I don't know that I would file in your case.

Also, one of the things I teach (and basically beat to death) in all of my BSA trainings, is that front line staff should ask questions. Using your scenario, if I were the teller the first thing I'd ask would be something along the lines of 'are you buying a new car?' or any open-ended question that would help me understand what the large withdrawal was for.

If we don't teach front line personnel to ask questions and actually communicate with our customers, that leaves personnel responsible for BSA monitoring and filing with a lot of questions such as yours. And needless to say, it makes our BSA lives quite difficult at times.
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#1239649 - 08/26/09 06:09 PM Re: SAR Reportable Transaction Miss Banker
fnbgal Offline
100 Club
Joined: Mar 2006
Posts: 140
CA
With large cash withdrawals, we like to approach it from a safety standpoint especially if the customer is elderly. Just with walking out the door with that much cash, we are concerned about their security, but there are also a lot scams going on and we want to make sure they are not a potential victim.

It makes it much easier for the branches to ask from this approach rather than just asking what they're doing with the cash.

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#1239869 - 08/26/09 08:29 PM Re: SAR Reportable Transaction fnbgal
nemsi Offline
Gold Star
Joined: Nov 2005
Posts: 383
I absolutely would not file a SUSPICIOUS ACTIVITY REPORT on a customer- obviously a known customer with an established relationship- just because he legally withdrew his own money. Just because he is retired does not mean that he is necessarily elderly.

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#1240747 - 08/27/09 09:26 PM Re: SAR Reportable Transaction CrashDavis
Jessesgirl Offline
Member
Joined: Nov 2008
Posts: 54
There's No Place Like Texas!
I also would not file a SAR for a single large cash withdrawal. I've spoken with my auditor about this and I label those as "unusual but not suspicious at this time." Who are we to say that he didn't take that money and buy a new motorcycle so he can travel the world? Now, if it happened a second time and it couldn't be explained that's a different story....
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