In January we had an account opened with a customer who was a self employed pharmacist. He opened a personal checkng account with a secondary signer and deposited $100.00 but soon after his account started receiving ACH Deposits with a sec code of CCD from two different pharmacies ranging in amounts of $4,000.00 to $18,000.00. The customer in question is an owner of both of these pharmacies. The secondary signer only shows up on one of the business accouts as a co-owner. When an inquiry was made to the customer regarding the business transactions going through his personal account he said that he would come in and open a business checking account. Shortly after checks ranging from $6,000.00 to $9,000.00 started clearing the account made payable to himself and the second signer on the account bringing the balance down to two hundred dollars. The checks were deposited at two diferent banks. The account was closed out May 21, 2014. Based on this information would it be prudent to file a SAR on the transactions that took place or was the bank closing the account sufficient?

SAR!!!

First- it's good that you shut the account down. No good could have come from keeping that account around.

Second- I agree that SAR is in order.

Strongly agree

This is a definite SAR. Be sure to include all of the information in the SAR as this looks like perhaps proceeds from a pill mill.