I have this customer depositing a lot of checks from different people into his checking account and then coming in and taking large amounts of cash out. When the teller asked him about it he said that he was selling a bunch of stuff on ebay and the cash was to pay the sellers back. Its bad enough he's structuring and using his personal account like a business but it appears hes selling guns through the mail. I call the local FBI and they just say send us a copy of the SAR when you're done. They never asked for his name or anything. Unbelieveable.

If you think he is structuring, file the SAR. Document who you spoke to at the FBI and send them a copy of the SAR as requested. Other than closing the account, I'm not sure what else you can do at this point.

The clearest fact is that he is running a business through a personal account; that alone is the basis for closure. You don't have to get into the messy stuff.

My first SAR on this customer would be my last... My second call to the FBI would be to give them the DCN on the SAR that I filed, not to give them a copy, but that's just me.

from your description it doesn't appear to me he is structuring, and what he is selling on ebay has no bearing on if a SAR should be filed. Now, if there are other details you've left off that indicates to you structuring is taking place, then by all means, you should file.

Sorry I should have included more details. He withdrew two different amounts a week apart that totaled over $10,000. While researching the information, I discovered he was heavily into guns and possibly selling them on-line because of the information that was on the memo lines on the checks deposited into his account from people all over the country. I thought you had to have a license to sell guns and thats why I thought it was illegal to do it through the mail. On some of his blogs, he had that he was the "angel of death" and it is referred to many times to how many guns he has. I thought the FBI would be concerned about that, but apparently they aren't and just told me to "fax" the SAR to them. I am filing the SAR for structuring and then will mention the other information in the SAR. We are either going to close the account or have him change it to a business account, we haven't decided yet. My first intention was to close it immediately but after the FBI sort of took a low interest, maybe we overreacted.

I think you are mis-reading the FBI reaction.
I doubt they will give you any other type of reaction and they are probably getting many such reports right now as sales of guns are on the increase.
I would definitely put all the information you have in the narrative and fax it to them as requested.

I would also close the account, unless you want to be known as the bank where the "angel of death" has his account. Just my opinion.

A former Bank had a policy against banking firearm dealers amoungst a long list of others. They would have closed the account

Thanks for everyone's input.

anyone can sell a firearm online, however it has to be shipped to a liscenced firearm dealer and picked up by the customer. The dealer will usually charge a fee for their role in the transaction. At least that is the way it is in MN.

Are you filing a SAR for his involvement with guns or for Structuring? Sounds like you need to research gun sale laws in Maryland. I personally know two dealers in other states. It's not against the law, but I don't know about the mail. You have two instances separated by a week where you think that's structuring? OK I guess. Based on your two accounts above, I would (as Ken suggests) either close the account or make him get a business account. Assuming using the mail is legal and he has a license, I think you are over reacting. You need to look at how you feel about guns politically and be honest. Would you file a structuring SAR on anyone else for two withdrawals a week apart?

Also- if the individual does have an Federal Firearms License (FFL), he could (and should) be shipping to an FFL dealer. You cannot mail firearms unless they are going from one FFL to another. However, the individual picking up the firearm could still be mailing the check to your customer, as they wouldn't pay the dealer anything except the FFL transfer fee.

In a nutshell, the bank needs to Know Thy Customer so that you fully understand just what his business is and, if you wish to retain him asa customer, get him into a business account.

IMO, the only thing you should have against this guy is the "angel of death" thing. That is scary, don't get me wrong. I agree with Cornhusker in that your decision to file could be based on personal feelings. People buy and sell guns all the time, and they are often transferred via US Mail. I don't think it is the bankers's job to pass judgement here, unless your FI has a policy of not banking firearm dealers. Again, the "angel of death" thing would concern me, but that is it.