Ok, something in this situation just doesn't seem right to me, and I thought maybe someone here might be able to click the light on. Or maybe quiet the nagging little voice in the back of my head. Whichever - either would be appreciated.

We have a customer who keeps ~$1,000 total in his checking and savings accounts. For the 2nd time in 2 months, we've filled out a CTR on him for cashing a check just over $10,000. (Why the tellers aren't putting a check hold is another issue we're working on...)

These checks are drawn off a business account (at a bank on the opposite coast) and payable to the customer personally. It's a national recycled paper manufacturing company. He is a regional manager for this business and states that the funds are to pay commissions to his employees.

The first red flag that went up for me was paying employees in cash. Not the norm around these parts.

The second was, if it's to pay his employees, why is it payable to him, and why is he cashing it off his personal account?

Is anyone seeing something here that I'm not? Or am I just being paranoid?

He's "cashing it off his personal account" because he doesn't have a business account with you. If I received a $15,000 check from a business on the left coast, and wanted to cash it, I'd have to cash it off my personal account here on the right coast. No choice.

As for whether the transactions themselves are suspicious, why not consider contacting the remitting company and asking if this is a norm for them? I think its questionable myself, but I don't know either your customer or the remitting company.

If your suspicions continue after the contact, SAR this puppy.

Right or wrong...many companies feel that there is a special impact made when they use cash to pay for bonuses and commissions. This does not necessarily mean that the amount is not being reported to IRS.

Ok, gotta resurrect this discussion...

We're now wondering if we should be filling out the CTRs with the names of the people he's giving the cash to, since they're the actual final beneficiaries of him cashing these checks. (Yes, he's still doing it...) We never see them, so it's going to be difficult.

He says he's cashing the checks to pay his employees their commissions or bonuses or something like that.

So, since we have actual knowledge that the cash (at least in part) is not ending up with him, does that mean he's going to have to give us a list of who's actually receiving the cash - names, addresses, ss#, birhtdate, occupation, DL #'s - so we can fill out a Section A for each of them?

I really dislike this whole situation, but I can't get the branch manager to tell him "no". Customer service for a long time client, and all that.