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#1962082 - 09/15/14 08:58 PM Suspicious cash deposits
Calmeida12 Offline
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Joined: Sep 2012
Posts: 249
I need several opinions on this. Attorney (specializes in foreclosures) customer has deposited over $350,000 in cash so far this year. In 2013, $175,000 in cash too. Some deposits as big as $175,000 at once in $20 bills. The most recent deposit was $80,000 in $100s. When questioned, he mentioned that he has being accumulating client payments since 2009 and that he has also sold some assets. He then wires the funds immediately to a private bank. SARs have been filed. Should I contact law enforcement?

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#1962094 - 09/15/14 09:21 PM Re: Suspicious cash deposits Calmeida12
Sunshine Lady Offline
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Sunshine Lady
Joined: Apr 2014
Posts: 590
I would report him to the state bar especially if it is an IOLTA. That explanation does not even make sense. What lawyer holds funds since 2009 and not deposit or maybe not even pay taxes on it. He knows the law or should know it better than we do. File CTR's, SARS and report to bar.
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#1962102 - 09/15/14 09:29 PM Re: Suspicious cash deposits Calmeida12
Elwood P. Dowd Offline
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Next to Harvey
The bar association is not a law enforcement agency. You have no more right to report an attorney's financial transactions to them than you would to report a doctor's transactions to the state medical board.

If there is any possibility that client funds are involved (that doesn't seem likely given the nature of his practice) sit down with your attorney and figure out whether the activity suggests those client funds are being abused. File SARs every day if you like, but let your attorney decide if and how you will report to the bar association.

It would take some real guts...
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#1962126 - 09/16/14 10:17 AM Re: Suspicious cash deposits Calmeida12
Pat Patriot Act Offline
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Joined: Apr 2009
Posts: 450
In your shoes, I would reach out to law enforcement only if I had a good relationship with an agent or investigator.

Personally, I've never had good luck or response from "cold calling" law enforcement to notify them about a SAR. Unless you had legitimate indication that the case would be a high priority to them, let it go through the SAR Review Team.

In my opinion, contacting Law Enforcement about a SAR is redundant in most cases, and does little more than to create the appearance of swift and strong action. If that would impress your bosses, by all means, proceed.

tl;dr: Filing a SAR is a notification to Law Enforcement.
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#1962466 - 09/17/14 01:31 PM Re: Suspicious cash deposits Calmeida12
John Burnett Offline
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Cape Cod
There are typically specific events that require a call to the Bar Association or IOLTA Committee at the state level if the account is an IOLTA account. That's part of the usual IOLTA program requirements. But that doesn't give you license to report other events to that group.
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#1962756 - 09/18/14 12:56 PM Re: Suspicious cash deposits Calmeida12
WonderWoman Offline
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Joined: Mar 2007
Posts: 2,108
gone fishin'
I've talked with many different SAR review teams across the country & due to the volume, the delay in receiving them and the extreme tiny print - they actually prefer you contact them with the "fun" SARs. I highly recommend reaching out to your local SAR team and coordinate a meeting to learn their processes and what SARs are important to them. Different teams focus on different crimes. They also can tell you what trends they are seeing and what to look out for.
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#1962936 - 09/18/14 06:15 PM Re: Suspicious cash deposits Calmeida12
charlied Offline
Member
Joined: Oct 2009
Posts: 94
TN
Hmmm, never thought of that. How do you find out who the local SAR review team is?

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#1962944 - 09/18/14 06:32 PM Re: Suspicious cash deposits Calmeida12
joser Offline
Member
Joined: Sep 2005
Posts: 68
NJ
If you ever had a request from LE - I'd start with them because they either are on it or it came from the SAR task force. Or contact your local IRS CI (criminal investigation) agent. We maintain a list of the task force which has a representative from various LE agencies.

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#1962959 - 09/18/14 07:05 PM Re: Suspicious cash deposits charlied
Elwood P. Dowd Offline
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Next to Harvey
Quote:
How do you find out who the local SAR review team is?


The easiest way is to call the DOJ office where your bank is located and ask for the AUSA who deals with SARs filed by banks. He or she is probably a member of the team, but will definitely know whom you should contact. (Be discrete if you have not yet filed the SAR.)

Many states have more than one district; e.g. Tennessee has three, eastern, western, and middle. Do a Google search "Department of Justice Tennessee" and the various offices will be listed in your results. The one whose phone number has the same area code as your bank is probably yours, but you will need to ask. (Their jurisdictions are not actually denominated by area code. wink )

The TnBA generally has members of the SAR review team at its BSA/AML school every year. This year, the guy was from IRS/CID. Next year, they are inviting someone from the DOJ.
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In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.

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#1962997 - 09/18/14 07:45 PM Re: Suspicious cash deposits Calmeida12
charlied Offline
Member
Joined: Oct 2009
Posts: 94
TN
Excellent information. Thanks so much!

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