I am trying to make sense of some unusual activity. Generally we would question the individual and try to get some info from them but at this time the subject is unavailable for questioning, and we do not want to alarm them that we are suspicious.

An individual has over the course of about a year brought in roughly $70K in cash all in small dollar amounts $200-$1500 mostly deposited via ATM. Approximately 85%-90% of the funds coming into the account go back out in small purchases ($20-$40) at 2 gas stations. We are talking $100-$175 per day every couple of days). The other source of funds in the account is an automatic payroll deposit. The other debits consist mostly of fast food purchases, bill payment and movie rentals.

The activity seems odd to us but I am having a hard time figuring out what is going on. My initial thought was maybe laundering through prepaid cards but the amounts are kind of odd for that.

Does anyone have any thoughts?

Approximately 85%-90% of the funds coming into the account go back out in small purchases ($20-$40) at 2 gas stations.

What do you mean small purchases - $20 - $40 in even dollar amounts?? How old is this person. Sounds like they are buying beer and selling it to minors.

Maybe I am way off here but the first thing that popped into my mind was lotto scratch & win tickets?

You don't win all that often.

They are not even dollar amounts. $41.50, $46.69, $25.70, $14.82 etc. They are visiting multiple gas stations in a day multiple times a day. I am talking on one business day 6-7 purchases at these gas stations.

The person is in their late 20's. In April alone so far they have made over $1400 in these small purchases at the gas stations.

does the gas station sell money orders?

You have two options:

1) Call him up and find out what he is doing. File SAR afterwards depending on the answer and either leave the account open if the answer is plausible or close the account if it is not.

2) File the SAR and close the account.

"An individual has over the course of about a year brought in roughly $70K in cash all in small dollar amounts $200-$1500 mostly deposited via ATM."

What is the customer's stated occupation? Maybe they do freelance or side work and get paid in cash?

You will never know unless you ask.

As stated above the individual is an employee of the bank so their occupation is known and income accounted for and the individual is on FMLA so we cannot contact them.

I think at this point we are just going to wait until the individual comes back from leave (if they ever do) and have a chat.

Thanks for all of your input

This is a bank employee?? I don't remember reading that.

Have you tried a site visit to the gas stations? Long lines at the Kiosk but not at the pumps? Selling bath salts or some other dubious product that your customer might be re-selling? Happened in my neighborhood....

the individual is on FMLA so we cannot contact them.

What does that fact have to do with the price of tea in China??? This is not a work related question. You would contact any customer that was doing this. In this role - they are nothing more than a customer of the bank whom you are trying to figure out if you want to keep (employee or not).

I'm sorry but I did not read anywhere above that this was an employee - that would make me want to get clear and reasonable answers to the questionable activity, sooner rather than later. Something else that isn't mentioned is how long is he out for - if you are waiting to question him because he has a few days left is one thing, but how much longer are you going to continue watching something possibly suspicious going through your bank????

Definitely seems like shenanigans of some sort.