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#1419393 - 07/23/10 05:46 PM SAR or No SAR?
Anonymous
Unregistered

Customer of several years enters the bank and asks to do a currency exchange of approximately $25,000 from small bills to large. We refused to conduct the transaction.

Customer does have a retail business but this transaction was in far in excess of what he normally deposits or withdrawals.He has never done an exchange. Also, word got to me that he may be in default on a loan at another institution. Possibly keeping has cash out of bank accounts in order to keep it. Not sure if this rises to level of criminal activity?

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#1419404 - 07/23/10 05:59 PM Re: SAR or No SAR? Anonymous
HappyGilmore Offline
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Joined: Jun 2004
Posts: 19,318
Pulling people out of the ditc...
what would you think in the above was criminal in nature?
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#1419452 - 07/23/10 06:34 PM Re: SAR or No SAR? HappyGilmore
Anonymous
Unregistered

If I knew it was criminal in nature I would obviously file. I am not sure and don't know if defensive filing is justified. It's not a crime to have cash or conduct cash exchanges. This is just unusual for this customer.

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#1419480 - 07/23/10 07:10 PM Re: SAR or No SAR? Anonymous
HappyGilmore Offline
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Joined: Jun 2004
Posts: 19,318
Pulling people out of the ditc...
Does unusual equal suspicious? I don't see that it does, but you may have a differing opinion. the various agencies have asked banks to not defensive file.
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#1419571 - 07/23/10 07:57 PM Re: SAR or No SAR? HappyGilmore
Anonymous
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I agree with you on that for sure. I am very conservative in my approach to filing as I don't want to put someone in the line of fire (so to speak) without ample evidence of criminal behavior. Guess I just wanted a bit of feedback/confirmation. Thanks a bunch Happy. TGIF

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#1419865 - 07/26/10 05:27 PM Re: SAR or No SAR? Anonymous
kw004h Offline
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Joined: Nov 2009
Posts: 219
Chicagoland, IL
Why exactly did you refuse this transaction?

This may be irrelevant, but if you had done the transaction, you would have been obligated to file a Currency Transaction Report. Then there would be some 'record' of this transaction for this customer if the agencies are looking for him.

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#1420024 - 07/26/10 11:03 PM Re: SAR or No SAR? kw004h
Anonymous
Unregistered

The Supervisor at the branch in question refused the transaction as she was not comfortable based on past transaction behavior. I have trained them on possible signs of money laundering and this was a new (unusual) sort of transaction for this customer. We have customers that make "frequent" (the key word) exchanges and we are okay with this sort of activity. There are all kinds of legitimate reasons on why the customer may have attempted to conduct the transaction but we still reserve the right to refuse if it make us nervous. And the guys been a jerk on occasion so we don't feel we need to go out of the way to assist.

Thanks

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#1420041 - 07/27/10 12:19 PM Re: SAR or No SAR? Anonymous
Anonymous
Unregistered

I don't think this was money laundering. Around the $10,000 number, yes. But changing $25,000 at once generates a CTR. Absent some other type of indication or knowledge of criminal activity I would be fine with the transaction.

I think you are correct about him keeping cash due to loan default. But the only way this becomes a criminal issue is if he fails to declarge the cash to the court if/when the lender sues him or he goes BK.

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#1420534 - 07/27/10 08:33 PM Re: SAR or No SAR? Anonymous
Anonymous
Unregistered

It seems to me that SAR should be filed on the Supervisor for not allowing the transaction. They, in effect, were able to stop a CTR from being filed.

I'm still not sure why the transaction was denied. A customer of several years wants to do a banking transaction; isn't that what banks are for? Maybe the peson won at the casino? Maybe the person lost a parent and the cash was inheritance? Maybe they've been saving up to buy something.

Not everyone is suspicious.

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#1420557 - 07/27/10 08:53 PM Re: SAR or No SAR? Anonymous
Flair Offline
Junior Member
Joined: Jun 2009
Posts: 44
I agree with the above. The CTR records the "suspicious" activity. You can use that as documentation in the future if suspicious activity continues and warrants a SAR. I would do the transaction. Don't really see a need to refuse or SAR it!

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#1420813 - 07/28/10 03:20 PM Re: SAR or No SAR? Flair
Anonymous
Unregistered

I agree with the above 2 comments. Also, if I was the customer, I'd close my accounts and take my business to one of the other banks down the street. And, I'd tell probably 50 or more people what the bank denied me, for no good reason. Not a reputational risk I'd like to have at my FI. Not a good decision in my opinion.

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#1420826 - 07/28/10 03:33 PM Re: SAR or No SAR? Anonymous
Aggs Offline
Diamond Poster
Aggs
Joined: Nov 2009
Posts: 1,331
Hoosier Country
Originally Posted By: kw004h
Why exactly did you refuse this transaction?

This may be irrelevant, but if you had done the transaction, you would have been obligated to file a Currency Transaction Report. Then there would be some 'record' of this transaction for this customer if the agencies are looking for him.


I agree. I thought currency exchange was a service banks provided to their customers. I wouldn't have denied the transaction. I would have ensured the CTR was filed. If he is hiding money, he likely would have behaved suspiciously as soon as he realized a CTR would be filed. Then you have a reason to file a SAR. Rumors and speculations about what he may/may not be doing are no reason to deny a perfectly valid transaction as long as you document it properly.

Originally Posted By: Anonymous
Also, if I was the customer, I'd close my accounts and take my business to one of the other banks down the street. And, I'd tell probably 50 or more people what the bank denied me, for no good reason. Not a reputational risk I'd like to have at my FI.


I would do the same.
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Opinions expressed in these threads are my own and not my employer's.

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#1421226 - 07/28/10 10:58 PM Re: SAR or No SAR? Aggs
Anonymous
Unregistered

Orig Anon Here:

Thanks for all the comments. I still support the Supervisor's decision to deny the transaction and will not be filing a SAR on her. I have always been a big believer in going with your gut feeling. It's a small town and she knows her customers. She thought this transaction stunk and I have to support her. If we lose a customer so be it.

Thanks again!

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