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#1263684 - 10/08/09 04:10 PM SAR worthy?
ComplianceGurl, CRCM Offline
Gold Star
Joined: Jul 2007
Posts: 498
Customer wants to do a wire with cash. Policy states the money must be ran through the customers account first. Customer does not want this to happen because he claims showing this money in his account will bump him into the next tax bracket and he already pays the IRS enough. My gut is telling me to file a SAR on the basis of tax evasion. My head is telling me we are not the IRS police and I don't need to file. Help!! Thanks in advance!!

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#1263708 - 10/08/09 04:24 PM Re: SAR worthy? ComplianceGurl, CRCM
Hrothgar Geiger Offline
10K Club
Hrothgar Geiger
Joined: Jun 2005
Posts: 10,395
Jersey Shore
So, did you refuse to do the wire for the customer?

Secondly, and this comment is not directed at you, I think that "tax evasion" is going to be second only to "structuring" as the most plastic concepts ever in BSA/AML...

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#1263778 - 10/08/09 05:11 PM Re: SAR worthy? Hrothgar Geiger
Retread Offline
Power Poster
Joined: Oct 2003
Posts: 2,548
Whether of not you file a SAR is up to you, but the way I see it, the customer told you he intends to evade his income taxes and he is asking you to violate bank policy to help him do it. Those are two red flags that point to SAR in my opinion.
Politicians are like diapers. They need to be changed often and for the same reason.

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#1263826 - 10/08/09 05:43 PM Re: SAR worthy? Retread
ComplianceGurl, CRCM Offline
Gold Star
Joined: Jul 2007
Posts: 498
The conversation with the customer took place over the phone. He said he would be in and has not yet.

Yes, the wire would be refused if he did not move the money through his account.

Thank you both for your input! I know what to do. :-)

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