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#1701348 - 05/18/12 07:59 PM SAR Filing on a Non-Customer
CrashDavis Offline
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Supposed you have to file a SAR on a non-customer due to possible structuring. All the information that you have is name. No address and no social security number. Teller did not get any id. What do you do. Do you file and give name and the rest indicate unknown.

Thanks for your help in this situation.

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#1701350 - 05/18/12 08:00 PM Re: SAR Filing on a Non-Customer CrashDavis
rlcarey Online
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rlcarey
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Galveston, TX
How can a non-customer structure cash transactions at your bank?
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#1701385 - 05/18/12 08:30 PM Re: SAR Filing on a Non-Customer CrashDavis
CrashDavis Offline
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Checks were payable to an individual who does not have an account with our bank on a business that has an account with our bank over several days that exceed $10,000. The checks were issued on the same day and check numbers are in sequential order but cashed over several days. My question is since he got the checks on the same day and they are either $9,000 or $8,000 why did he cashed them on the same day. Since he did this, my opinion he did not want a CTR to be filed on him.
Last edited by CrashDavis; 05/18/12 08:37 PM.
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#1701389 - 05/18/12 08:34 PM Re: SAR Filing on a Non-Customer CrashDavis
rlcarey Online
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rlcarey
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If they are on-us checks, I would be filing on your customer and the additional suspect with as much information on the check casher as you can muster. The customer was a co-conspirator here.
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#1701395 - 05/18/12 08:38 PM Re: SAR Filing on a Non-Customer CrashDavis
CrashDavis Offline
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I wondered that, but I also questioned that maybe the customer of our bank thought he would cash the checks the same day but on the other hand why did the customer just write one check.

Thanks for your help. I appreciate it.

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#1701399 - 05/18/12 08:40 PM Re: SAR Filing on a Non-Customer CrashDavis
rlcarey Online
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rlcarey
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Galveston, TX
Yup, been down this road once or twice.......
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#1701402 - 05/18/12 08:41 PM Re: SAR Filing on a Non-Customer CrashDavis
CrashDavis Offline
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Agree with that.

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#1701409 - 05/18/12 08:44 PM Re: SAR Filing on a Non-Customer CrashDavis
devsfan Offline
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It takes 2 to tango; if your customer had not issued multiple checks we would not be having this conversation

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#1701411 - 05/18/12 08:45 PM Re: SAR Filing on a Non-Customer devsfan
Elwood P. Dowd Offline
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Ditto, your customer either agreed to it or asked for it. There is no reason for you to try to sort them out.
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#1701417 - 05/18/12 08:51 PM Re: SAR Filing on a Non-Customer CrashDavis
CrashDavis Offline
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I have just learned that the reason was that our customer asked the individual not to cash the checks until they tell him to due to the fact that they did not have the money in their account to cover the check. That is the reason they were cashed over a two week period of time.

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#1701438 - 05/18/12 09:13 PM Re: SAR Filing on a Non-Customer CrashDavis
Elwood P. Dowd Offline
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If the account balance in that same period corroborates the statement, I might buy that. Be prepared to sell it to the examiner too.
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In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.

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#1701440 - 05/18/12 09:16 PM Re: SAR Filing on a Non-Customer CrashDavis
CrashDavis Offline
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I verified that with the bank statement and it agreed with what I was told. I am going to document this in my file and watch the account very closely.

Again thanks for each of yours input. Very helpful.

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#1701443 - 05/18/12 09:22 PM Re: SAR Filing on a Non-Customer CrashDavis
rlcarey Online
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rlcarey
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Galveston, TX
Where did the deposits into the account come from to cover these checks? Why were the checks written to the non-customer in the first place?
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#1701451 - 05/18/12 09:52 PM Re: SAR Filing on a Non-Customer CrashDavis
CrashDavis Offline
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The deposits were from legitimate funds. This was verified. The checks were written for goods sold to company. This is a business that buys produce in bulk. It is a business that we understand.

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