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#1733645 - 08/22/12 02:56 PM cash withdrawals every 5-10 days
Compli(cated) Offline
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Wisconsin
We have an account that receives multiple electronic deposits (for varying amounts from $20 - $950)each day from Switch Commerce, sometimes up to 10 deposits per day. A quick search tells me that Switch Commerce is a credit card processing company of some sort.

Every few days (sometimes two days in a row, sometimes a week or 10 days apart) the account owner withdraws $5,000 in cash - it never triggers a CTR.

The person has other accounts with a direct deposit for a salary from a hospital. Employment at a hospital is also what she reported when applying for a loan.

Does anyone have any suggestions of what the transactions might be for and whether this sounds "suspicious enough" for a SAR?
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#1733658 - 08/22/12 03:09 PM Re: cash withdrawals every 5-10 days Compli(cated)
Retread Offline
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It sounds like your customer is running a side business. You need to find out what it is before you can make a decision on whether or not to file a SAR.

Switch Commerce Specialties
Credit Card Processing, ATM Processing, Merchant Account, Merchant Services, Mobile Credit Card Processing, Payment Processing

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#1733670 - 08/22/12 03:15 PM Re: cash withdrawals every 5-10 days Compli(cated)
E.E.G.B Offline
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Switch is the company that handles the swipe machine that attaches to your smart phone, so that you can process credit card transactions using your phone. (I know this because we can use it to accept credit card payments for Girl Scout cookies.)

Not sure what she might be selling that would generate that kind of income - she could have a secondary business selling at swap meets or something, but you'd have to find out more about that. If she is dealing in something (not necessarily illegal) she could be accepting payments then using the withdrawn funds to re-stock her supply. I think it is definitely worth a conversation.
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#1733674 - 08/22/12 03:18 PM Re: cash withdrawals every 5-10 days Compli(cated)
BrianC Offline
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Illinois
Quote:
ATM Processing


It's also possible that your customer owns/operates an ATM and they're withdrawing the cash to replenish it. A search of the BSA threads will yield a number of discussions on proprietary ATM monitoring requirements.
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#1733676 - 08/22/12 03:23 PM Re: cash withdrawals every 5-10 days Compli(cated)
Elwood P. Dowd Offline
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Either way, you have it set up as a consumer account. It appears that it is not. Doing some enhanced due diligence (calling the customer and saying Whussup?) is easier and less time consuming than filing a SAR.
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#1733714 - 08/22/12 04:12 PM Re: cash withdrawals every 5-10 days Compli(cated)
Compli(cated) Offline
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Wisconsin
Thanks everyone! I will check with the branch to see if they have any insight and contact the account owner for an explanation if they don't.
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#1733726 - 08/22/12 04:20 PM Re: cash withdrawals every 5-10 days Compli(cated)
Princess Romeo Offline

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This could be an excellent cross-sell opportunity if your customer has started a side business. Or your customer could be involved in a scam. Either way, you are not going to know until someone talks to the customer.
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