Customer takes $9000 every month, sometimes twice a month. A SAR was filed originally because there were two back to back business day withdrawals for $9,000. We have filed a continuing SAR because the customer is still withdrawing $9,000 once a month. I interviewed the customer, they do have a lot of money and the wife goes to Vegas about once a month. He goes with her every once in a while as well. He says they treat them very well. In light of this new information, I would say that this activity is normal and expected behavior. But I am nervous to document that and not file the SAR report. Would anyone have any desire to weigh in on this situation and what they would do? I know they are just opinions but I am really in the weeds on this one.

When you reach the next 90 day review, write up your summary of the new information, and how this information leads you to conclude that you no longer consider the monthly withdrawals suspicious.

That said, if you encounter another seemingly structured set of transactions, such as the one that initially prompted you to file, you'll want to make sure you're still identifying and reviewing these appropriately.

I hate to say this because these SARS seem so pointless, but I would find it hard to believe he's not choosing that amount to evade the CTR if for no other reason than to be contrary. If the bank does not want to be any tougher on him about the amount of those withdrawals, I would continue to file until I could get some clearance with my particular examiners. We have similar situations with our wealthy gamblers and it's a total pain because the bank does not want to upset them and doesn't believe they are doing anything wrong at all.

I agree with JacPCB. Unless you learn of anything to the contrary, I'd sum it up and be done with it. The filing of defensive SARs seems pointless and you are certainly not going to get any 'clearance' from an examiner.

Has anyone ever ran into an examiner issue when they sum it up and call it expected behavior? And what do you mean by not going to get any 'clearance'. Do you mean they won't bless it?

All any examiner or auditor has ever told me is if I felt like I needed to file. File. If I felt like I didn't need to file, document. I've never had someone say -- oh! That's good. You don't need to file on that. Just that if I didn't file, maybe my documentation might be a little lacking, or perhaps someone else needed to review the information with me.