We conducted a cash count at one of our branches. The head teller's window was counted and found to be $181.25 short. The count was done first thing in the morning and no activity took place since the teller balanced previously. She indicated she was over $23.67. Could not explain why the difference. The head teller is responsible for the vault and ATM also. The vault was over $10,000.00 and the ATM was short $12,490.00. There is a lot of questionable entries to the ATM over the past several months.

Another part of the story, the head teller seemed very nervous while we counted her window and asked regarding the $181.25 shortage what will happen to her now. This was before we balanced the vault and the ATM. She then left for lunch and had a bad wreck. She was supposed to be back from lunch at 1:00 and wreck occurred at 2:30. The location of the wreck was no where near the bank. We do not believe she was coming back to the bank that afternoon. The wreck was a head on collision. She is going to be unable to come back to work for 6 months to a year (that is if we allowed her to come back). We can terminate her for abandoning her post and other areas for not doing her job. We have been unable to tie the money to any of her accounts. To this point she has not confessed to anything.

My question should we file a SAR on this indicating that she is responsible for these two areas where the money came up short and over.

Thanks in advance.

It does sound like an insider SAR to me. If indeed there was a loss to your bank, the regulators can question your process if the SAR is not filed. You are identifying her as "suspect", not actually accusing her in court, and you are within the safe harbor - what is the reason not to file?

I would not think that a loss or no loss would be part of the process.

If you determine that insider abuse was a factor file if not do not file

If you can pin the differences as her taking the money file.

I would think that you would need to do a little more digging into the ATM differences.

I would not file every time I had a teller short $200.

You could possibly claim a case based upon her signature on the ending proof and the cash in her draw if the cash count is approprate.

ATM differences could be an issue with the machine, theft or difference with other tellers (possibly a shipment error).

Sorry if it is not the answer you are looking for.

Either way this does not seem to be a teller you wish to keep on staff.

I don't know if you have sufficient information to file a SAR on her for the vault and ATM, while she may have management responsibility for it, i'll assume it is under at least dual control and another employee has shared / joint responsibility. So, if you file on her, i'd think you'd be filing on the 2nd employee as well.

Happy, that is the problem, procedures is the entry of the ATM is to open the ATM under dual control but she did not follow the procedures. She would open the ATM by herself. That is the problem. The reason I feel a SAR needs to be filed is that she is the person responsible for these areas. Also in our research we do not feel it is a fault of the machine. The shortage of her window is not a reason for filing a SAR. It is the ATM shortage that is the reason.

I would file and be done with it if she had sole control. How can that happen anyway?

She balanced her cash drawer at EOD. The next morning, prior to running any transactions, the cash audit on her drawer comes up short. Pretty clear evidence that she's fudged her figures. Why would you not file a SAR?

I am confused on how she could have sole control of the ATM. Would other also have access to the ATM?
Why would she enter the ATM by herself?
Who granted her the ability to access the ATM by herself?

It appears that controls were lacking over the ATM. I would think that there should be more blame to pass around. I would find it difficult to place the lack of controls over the ATM on a teller.

Did she or anyone else have access to her teller box prior to the cash count?

While I am no longer a BSA Officer and I'm not familiar with the new format - can you still file for 'Mysterious Disappearance'?

Yes, you would mark 35e "Embezzlement/theft/disappearance of funds".

Also, if you believe she took the funds from the ATM why would not also believe that she took the funds from her drawer?

What's going to determine whether or not you file a SAR is whether or not you believe the cash differences are the result of errors or misappropriation/wrongdoing. It sounds like you're leaning toward the latter. If misappropriation is the conclusion you draw from your investigation, then filing a SAR is the appropriate response.