Thread Options
#2016825 - 05/28/15 10:44 PM SAR or not?
lisa_dooley Offline
New Poster
Joined: Sep 2014
Posts: 8
South Carolina
We have a business customer who we file CTRs on fairly regularly. We have filed 12 this year so far. They recently withdrew $10,000 on 5/26 and $10,000 on 5/27. One signer withdrew on one day and another signer withdrew the next. What is your opinion on if we should file a SAR or not since we have filed CTRs previously?

Thanks,

Lisa

Return to Top
BSA/AML/CIP/OFAC Forum
#2016838 - 05/29/15 03:12 AM Re: SAR or not? lisa_dooley
JacF Offline

Power Poster
Joined: Nov 2001
Posts: 6,719
PA
Given that the customer has a history of cooperating with reporting requirements, if this were my customer, it would take more than one or two withdrawals for me to conclude that they have decided to no longer comply. But it's worth sticking a pin in this one in case it marks the beginning of a new pattern. The only way you'll know is by watching to see what happens next, while at the same time reviewing your understanding of the customer's past history.

When looking back, consider not only the 12 CTRs, but what happened between them. Is the customer making multiple withdrawals in a week? Do a week's worth or a month's worth of withdrawals aggregate to roughly the same amount as other weeks or months? Do they regularly conduct withdrawals above and below the CTR threshold? How much of a pattern change is this when you look at the big picture?

Don't forget to check out other possible causes for the change. Did the branch lack a sufficient cash supply to meet the customer's request on the 26th, prompting a second withdrawal? Did the customer discover that their insurance will only cover a certain amount of cash on hand at their premises?

I hope this gives you some useful tools for better understanding these transactions.

Return to Top
#2016862 - 05/29/15 01:06 PM Re: SAR or not? lisa_dooley
PrimeTime Offline
100 Club
PrimeTime
Joined: Nov 2014
Posts: 173
I agree with JacFSB. I'm assuming that we don't have all the details here, which makes it more difficult to try and comprehend.

Of the 12 CTRs filed, were they for cash in, or cash out? If it's a consistent cash in stream and all of a sudden you start seeing cash withdrawals, that is certainly out of the pattern although I wouldn't file on that alone.

Does the customer have a business need for the cash withdrawals (check cashing business, scrap metal buyer, etc.)? If so, enhanced due diligence would probably find that there was an influx in business due to season, time of the month, etc.
_________________________
Life is like a bicycle. To keep your balance, you must keep moving.
-Albert Einstein

CAMS

Return to Top
#2016872 - 05/29/15 01:31 PM Re: SAR or not? lisa_dooley
lisa_dooley Offline
New Poster
Joined: Sep 2014
Posts: 8
South Carolina
Thank you both for your input.

These are always withdrawals. The customer buys/sells gold, so depending on the price of gold some months the cash withdrawn is much greater than other months. The customer has withdrawn $10,000 in the past, just not 2 days in a row.

Lisa

Return to Top
#2016876 - 05/29/15 01:40 PM Re: SAR or not? lisa_dooley
Elwood P. Dowd Offline
10K Club
Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
The dilemma is well outlined. The only way to resolve it is to call the customer and ask if there is a reason why they withdrew large amounts of currency on consecutive days as they do not normally do that.

I don't know what they will say, but am fairly certain their answer will help you reach a conclusion one way or the other; e.g. if they suggest you "mind your own business" calculate when the SAR is due and start working on it.
_________________________
In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.

Return to Top

Moderator:  Andy_Z