I cannot count how times I have spoken to customer's of all types and backgrounds to finalize AML investigations. Do I speak to every single customer, no I don't. But do I have a conference call with those I deem higher risk? Yes, I do.
I don't come out and accuse them of money laundering, structuring or any crime. I simply inquire as to the nature of the account activity. For example, I have asked multiple customers about why they are conducting deposits and/or withdrawals on one day, which when aggregated, exceed $10,000. I have also spoken to customers who after years of no foreign wire activity have four or five in one month. I know this sounds crazy, but some times a conversation with a customer actually stops me from filing an SAR. Most of the time, the customer understands and is happy to explain.
To be honest, just because the employee thinks an SAR could/is filed doesnít mean the bank has violated the prohibition on disclosure. As Kathleen indicated, this is a very serious matter and if you cannot complete your investigation, you need to speak to the employee. Donít reference anything about an SAR. I would simply ask about the nature of the activity and why the transactions are being conducted in such a manner as to raise your suspicions that money laundering could be taking place. Iím sure there are other factors going on that you cannot post about, but you simply have to take prompt action on something like this.
"100 victories in 100 battles isnt the most skillful. Subduing the other's military w/o battle is the most skillful." Sun-Tzu