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#1408629 - 06/25/10 10:24 PM SAR-able

I'm struggling to not dig too far, so I need some help.

Customer withdraws total of $28,000, IN CASH, from three of his business accounts (LLCs). The money is deposited into one of his personal accounts. The next day, he deposits the $28,000, in the form of personal checks, back into each of the three business accounts. Note on each of the deposit slips states "payment from shareholder".

I mean, it's something that you say, "why would he do that", but I wouldn't know which SAR category to pick. Could I ask customer, yes; however, I don't want to tip our hand on any sort of filing. CTR was filed on original withdrawal of cash.

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#1408658 - 06/26/10 02:29 PM Re: SAR-able Anonymous
Kathleen O. Blanchard Offline

10K Club
Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,281
The one thing that strikes me is that it could be a fraud - he may need to "prove" that he has made certain additional capital contributions to this LLCs. If he is dealing with someone who probably won't audit the books he can show the deposited checks as "proof".

There would be no legitimate reason for him to do this.
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy

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#1408686 - 06/27/10 09:32 PM Re: SAR-able Kathleen O. Blanchard
MagicCity Offline

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Joined: Apr 2003
Posts: 3,003
Fort Lauderdale, Florida
If there is not a specific category, choose Other and type Suspicious Activity.
One of the reasons for filing is if the transactions, after performing your due diligence, - do not make sense.
This would seem to apply in your scenario.

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#1409191 - 06/28/10 09:33 PM Re: SAR-able MagicCity
West Coast Comp Offline
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West Coast Comp
Joined: Jun 2010
Posts: 350
Lost in the rain.
I agree with Kathleen, there is no legitimate reson for this activity.
Where I go there I am. smile

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