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#1641079 - 12/20/11 05:09 PM SAR for large cash deposit?
toni Offline
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Joined: Aug 2007
Posts: 18
We accepted $120,000 in cash for deposit from a new customer;however,customer is well-known by account officer. The customer has already provided us with explanation of source of funds (sale of house in MX) AND supporting docs, which consist of a property sales contract and copy of declaration of currency at an international bridge.

Q: Would you consider that the explanation of source of funds and documentation obtained would be sufficient to justify cash OR are other banks filing SARs for this type of transactions? Please advise.

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#1641106 - 12/20/11 05:39 PM Re: SAR for large cash deposit? toni
ACBbank Online
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ACBbank
Joined: Jul 2006
Posts: 3,959
New York City
If the customer claims the funds originated from the sale of a home and provided valid documentation to demonstrate such, I wouldn't file an SAR unless the customer attempted to structure the deposits.
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#1641110 - 12/20/11 05:54 PM Re: SAR for large cash deposit? toni
devsfan Offline
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Joined: Jun 2004
Posts: 1,927
NYC
IMO you conducted due diligence and received both an explanation and documents to support the explanation and I would not personally file a SAR based on these facts. Document this in your files, keeping copies of the documents provided by the customer.

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#1641417 - 12/21/11 10:32 AM Re: SAR for large cash deposit? toni
Elwood P. Dowd Offline
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Elwood P. Dowd
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Posts: 21,939
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Relying on the documentation you received, not the fact that the individual was well known by an employee, I think you have an adequate explanation for the source of funds. It should be run through your SAR decision making process, but I see no basis for filing a SAR.

FYI, some field examiners (government employees all) think there should be a box on the SAR that says "No one should have that much money." wink
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