Is this scenario SAR worthy?
We have a customer that is middle eastern descent. He is an assistant mathematics professional at a university. Accounts maintained include savings and deposits with YTD average of approximately $350,000. He recently wired $100,000 to Lebanon which is the first time this occurred - out of the ordinary. Bank staff is not familiar with him. Is this SAR worthy? Doesn’t feel right.

"We have a customer that is middle eastern descent" Who better to wire funds to Lebanon?

But if it does not feel right it needs more investigation.

I would need more information.

My answer may be over simplified, but here it goes.

See if you can find anything about the recipient on the internet. If you still do not feel comfortable, ask the customer about the wire. If he does not cooperate, close the account and file a SAR.

I agree with Ed. There is not enough information to determine whether an SAR should be filed. BC has offered some practical advice. Look for an internet footprint on the beneficiary or the address listed in the wire. More importantly, how was the wire funded? Have the funds been there for a while or did the customer make a recent deposit and then wire out the funds?

At the end of the day, you should reach out the customer and ask. There could very well be a reasonable answer to this.

The high average balance leads me to believe that this isn't a case of funds being churned quickly. And the customer's ethnicity suggests that he may have family and/or business associates in lebanon. I'd go through the research steps noted by previous posters, and unless something alarming pops up about the individuals involved, or there are more out-of-pattern transactions, file it in the "reviewed- no SAR filed" file.

Why are you thinking this is SAR worthy?

Because to funds to the middle east? Out of the ordinary for the customer? The size of the wire? Because you don't konw your customer?

How was the wire sent? Online banking product? Or through a banker in a branch?

The purpose of the wire would have been a good question to ask on the front end if through a banker...

I agree. If you don't capture the purpose of each foreign wire, I would recommend doing so. At least you have something to go on when reviewing transfer activity.

We have discussed having the purpose on foreign wires in the past but if its for illegal activity the customer will not disclose that; i.e - funds for relative vs funds for terrorist financing. Also - the same goes for discussing with the customer. If it for illegal activity he is not going to disclose that fact. We monitor activity and anything out of the ordianry is what we research in more detail.

For the discussion with the customer it is not exactly what the customer says but what he does not say and how he acts when responding to the questions.

I have found that asking the purpose provides an opportunity to improve transaction transparency. You can occasionally identify individuals that become uncomfortable with the additional questions, sometimes to the point of changing their story or cancelling the wire. Good info to know.

By far, most individuals conducting frequent foreign wire transfers are not surprised that they have to document the purpose of the wire and do not hesitate to provide the info.

This actually became an "expectation" of our regulator years ago.

There's also the very real possibility that somewhere along the route to the beneficiary, one of the banks handling the wire will require information on the purpose of the transfer, and everything will grind to a halt until that message works it way back to you and your customer and a response is sent. Getting the information -- truth or prevarication -- up front is rapidly becoming a best practice.