The bank has an account for a corporation. They have sold their account's receivable to a company who then wire's the funds into the corporation's account. Could this scenario be used to launder money and who do I notify after I file a SAR?

Thanks for your help.

could it be used to launder funds? not likely or obvious. i don't think a sar is required here. check the exemption provisions of the act.

Are there other circumstances that make you think that it IS laundering?

Just about any scenario could be associated with money laundering so it is good to ask questions. Do the transactions seem reasonable for the business being conducted and is the business well known to you?

Like good financial analysis, the answers to these questions may just prompt more questions than answers. But once you are satisfied with these you'll have what you need to know.

you are right andy, as they say "ya never know".

It doesn't appear to be a suspicous tranaction, based on the three criteria noted in the BSA. Specifically, it's not strucutred to avoid CTR reporting: it's not an unusual transactions for this type of customer; and, it's not known to be tied to an illegal activity.

Unless the wire came in, and a comparable amount was immediately wired out, I would not consider it suspicous.