existing customer since 2002
2010 purchased a fixer upper home mortgage held here at bank
checking account 3 cash withdrawals little over one week period
9900.00
9900.00
9900.00 + 200.00 atm withdrawal = CTR filed
customer explains to tellers as he makes large cash withdrawals he's having rock walls, fence and all new landscaping he saves money by paying contractor in cash.


site visit to home: new multiple rock walls, new fence, landscaping.
do we file sar?
TIA
lisa

Even though you are comfortable with the purpose of the cash withdrawals, you still have the apparent structuring. To me this would result in a SAR.

The fact that he did in fact have the work done on the house does not explan why he withdrew 9,900 x 3.

I would need to know why he withdrew in the maner that he did (without a satisfactory answer I would lean towards filing)

he admitted to tellers he's paying his landscaper in cash becuase he gets a discount.
not sure if this matters in opinions or not.

There is no law against paying someone in cash. The issue is did he structure the transaction to evade the filing of a CTR.

He's structuring his withdrawals. Is he doing it on purpose? Was he coached by the landscaper?

The only way I would not file for structuring is if he could show me 3 separate invoices for 9900.00 each. Otherwise he's structuring, even if it at the request of the landscaper. I'd also include the landscaper's info (as much as I have) in the narrative at the least.

Although I'm sure this is how the landscaper wanted the cash (I know of other instances similar to this), in my opinion it's still structuring.

Exactly, 20k in a week... why did he not just make one withdrawl?

IMO, three 9,900 withdrawals in a weeks time is textbook.

Textbook structuring Lisa!

Also, why did he make a $9,900 withdrawal and then also a $200 ATM withdrawal? You correctly aggregated in a CTR but I would think he did not anticipate that you would.

We sometimes see Saturday and Monday transactions that are aggregated in a CTR and I usually suspect that our customer did not expect that we would do so.