An employee of a business customer refused to provide SSN for a reportable transaction. Teller conducted the transaction. There is no reason to think that the employee is involved in any illegal activity. Is a SAR on the employee necessary just for the refusal to provide the SSN?

How about firing the teller for processing a transaction without the required information. That is where the breakdown occurred.

This has been happening for some time with different tellers and it was just discovered. Do you think a SAR is warranted on the customer's employee?

File a SAR for refusing to give TIN. Tell customer never to send that employee again to make a deposit for them in your Bank.

I would not be over anxious to file a SAR on customer activity when that activity could not have taken place without the complicity of a bank employee; the transaction should have been refused.

If this is a systemic problem your training and internal controls need reinforcement.

This sort of thing is understandable when a CTR is required only because multiple cash transactions aggregate to more than $10,000. An individual teller might not have been aware of other transactions. But when a single transaction by itself requires a CTR filing, the teller and/or teller system should automatically require the information for completing the CTR before completing the transaction.

Ken,

Regarding a SAR.

If after a person is told that it is legal requirement, and refuses to give the Bank the number, how is this different from a customer taking back part of the deposit when told that a CTR is required.

I agree that the teller should have not taken the deposit, but I feel a SAR is required.

If an employee shows up with the deposit and doesn't want to provide their SSN and leaves and then someone else shows up to make the deposit, it is not equavilent to structuring a deposit to avoid reporting. They just didn't want to take off their aluminum foil cap which is not breaking the law.

"but I feel a SAR is required."

So who are you going to file on? The customer or the teller, who broke the law?

If you want to call this a defensive SAR, so be it; however, I feel the refusal to supply the number is an attempt to avoid CTR reporting requirements.

Had a similar case at another bank once, called the employer and asked him to have his employee give us the TIN. Employer admitted that he hired illegals and they did not have TINs.

In an attempt to re-track this thread, I'll note that I'm responding to the apparent circumstance that this was a face to face transaction, not an attempt to get the number in connection with aggregated transactions.

I agree that refusing to provide the SSN should trigger consideration of a SAR and I would not call a decision to file defensive. However, my greater concern is that the employee carried out the transaction anyway. rlcarey seems to be rattling the same bars in suggesting that the employee be listed as a suspect on the SAR. I don't think either of us would actually do that, but if I did file a SAR on the person presenting the transaction I would feel compelled to include a paragraph describing the consequences for the employee. They would be significant.

Thanks for your input everyone.