Skip to content
BOL Conferences
Learn More - Click Here!

New Reply Thread Options
#1460249 - 10/27/10 06:29 PM Is SAR needed?
Anonymous
Unregistered

We have a commercial customer who opened an LLC less than 30 days ago using loan proceeds secured by a CD with our bank. His business is electrical contracting. Within three weeks the first check to potentially overdraw the account was returned due to NSF. He had promised to make a cash deposit to cover that item but did not show up (hence the return). In the last 6 business days he has deposited cash totaling $50K+. It is hard for me to conceive of a one-member LLC electrical contractor conducting a cash business. Do the facts require an SAR?

Return to Top Reply Quote Quick Reply Quick Quote
#1460256 - 10/27/10 06:35 PM Re: Is SAR needed? Anonymous
Here4Life Offline
100 Club
Joined: Feb 2010
Posts: 121
I would say if your suspicious, then yes file a SAR.

Return to Top Reply Quote Quick Reply Quick Quote
#1460264 - 10/27/10 06:43 PM Re: Is SAR needed? Here4Life
Kathleen O. Blanchard Offline

10K Club
Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
The cash business doesn't surprise me, the 50K in cash in 30 days does. If there is no explanation that makes sense and changes your mind, file.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

Return to Top Reply Quote Quick Reply Quick Quote
#1460637 - 10/28/10 02:37 PM Re: Is SAR needed? Kathleen O. Blanchard
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 47,517
Bloomington, IN
Quote:
LLC less than 30 days ago using loan proceeds secured by a CD with our bank. . . . . in the last 6 business days he has deposited cash totaling $50K+.


Not saying your situation is but this is a classic money laundering MO.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

Return to Top Reply Quote Quick Reply Quick Quote
#1464065 - 11/04/10 07:18 PM Re: Is SAR needed? Dan Persfull
Anonymous
Unregistered

Since my first post we have had an additional $50K+ added. Yes....it's SAR time....

Return to Top Reply Quote Quick Reply Quick Quote
#1464243 - 11/04/10 09:23 PM Re: Is SAR needed? Anonymous
Anonymous
Unregistered

Don't you just hate it when a SAR suspect is a loan customer! smile

Return to Top Reply Quote Quick Reply Quick Quote
Quick Reply:
HTML is disabled
UBBCode is enabled




Moderator:  MagicCity, P*Q, Truffle Royale