Customer is a shipping company specializing in the transport of cargo to and from the Yucatan Peninsula. Cash deposits into business account have suddenly increased since June - appears to be structuring as well. When questioned, customer stated that the cash deposits are payments from customers for freight expense for imports and exports. Since mid-June 2013 - cash deposits exceed $143,500.00.

Is this normal - being paid in cash ?? I think not but this is the first time I have run across this situation.

Thanks!

seems like an unusual business arrangement...although in the liquor industry customers must pay (at least in Louisiana) before they receive their goods - no credit. So, very cash intensive business.

File the SAR for structuring, but definitely mention the customer's explanation for the cash in the narrative. Note that it is a departure from his original activity and the denominations of the bills he deposits. If you find a respondent here who has some experience and can say it is or is not "normal," that's great, but put it in your SAR anyway.

Your SAR's readers may have enough knowledge to make the call without your analysis.

Just to add, for going forward, if the bank is going to retain this customer gain an understanding of their industry and the ins and outs of how works.

Does your commercial lending area conduct or have access to industry studies? See if they have resources that will help.

On import/export, the only cash payments I see regularly are 'cash to master' which is cash paid to the master of the vessel for port and miscellaneous charges. I never see actual payments for shipments or collections on account in cash.