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#2018348 - 06/04/15 02:45 PM SAR opinion
mdog76 Offline
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Joined: Jan 2007
Posts: 645
We are located about 90 min from a major resort and casino so access is pretty easy. We have a customer who frequents this casino regularly, so much in fact that the casino automatically debits their checking account. Since the beginning of the year, this customer has deposited $84,000 in cash and casino has automatically debited $121,000 as well. Outside of identifying a gambling problem, is this really suspicious?

Thank you.

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#2018350 - 06/04/15 02:47 PM Re: SAR opinion mdog76
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,700
Cape Cod
Based solely on the information supplied, I'd say no. But if, for example, the cash deposit transactions appear to have been structured, you'd want to consider a filing.
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#2018366 - 06/04/15 03:02 PM Re: SAR opinion mdog76
mdog76 Offline
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Joined: Jan 2007
Posts: 645
There have been CTRS filed during this time period, so structuring does not seem to be evident.

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#2018485 - 06/04/15 06:24 PM Re: SAR opinion mdog76
BSAAnonymous Offline
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Joined: Feb 2012
Posts: 165
Depositing cash? Source?

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#2018597 - 06/05/15 11:17 AM Re: SAR opinion mdog76
Pat Patriot Act Offline
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Pat Patriot Act
Joined: Apr 2009
Posts: 450
Are they retired? Could they be a professional gambler? Otherwise, what do they do for a living? What's their source of wealth? Where does the other $37,000 come from? How does your customer pay for / fund other expenses?
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#2019544 - 06/10/15 04:19 PM Re: SAR opinion mdog76
AquaMarine Offline
100 Club
Joined: Jun 2011
Posts: 156
New York, NY
CTRs are filed by the bank, with or without the customer's knowledge, when the aggregate amount exceeds the reporting threshold. The fact that the bank filed a bunch of CTRs does not mean that the customer is clean of structuring. With that being said, you may want to look at the WAY those cash deposits were made.

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#2020041 - 06/12/15 01:22 PM Re: SAR opinion mdog76
mdog76 Offline
Platinum Poster
Joined: Jan 2007
Posts: 645
Just now coming back to this. This customer operates an Elvis Museum here and appears to make enough to cover daily expenses. Looks like this money at the casino is discretionary income.

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#2020043 - 06/12/15 01:50 PM Re: SAR opinion mdog76
osucpa Offline
Diamond Poster
Joined: May 2011
Posts: 1,402
I would say no.

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