We have a customer that has purchased 11 cashiers checks with cash from 01/19/10 to 07/19/10 totaling $52,281 or an average of $4750. We did file a CTR on one transaction. All of these cashiers checks are payable to a lumber/construction materials store. It appears he is paying cash for his construction project.

Is a SAR deemed necessary given the average transaction and the length of time of the activity?

Purchased from a individual or business account?

What is it about the transactions that seems suspicious?

The cashiers checks are purchased by an individual. I guess what is suspicious is the amount of cash involved - however - it appears he is paying cash for construction. I think it is ok but want to bounce off BOL.

Depends upon what he is building; construction can involve a lot of money.

But where is the cash coming from?

If it is his own personal cash or he deposited funds from a loan from somewhere (we don't know if this is business or personal), I certainly don't care if he spends it at a home center on building materials.

The question here revolved around how it was being spent. If the source is questionable, that is another converstion. If the source cannot be explained, that could be worthy of an SAR.

Thanks for the feedback. He is making check deposits and then withdrawing cash. We know the source of the cash.