Skip to content
GeoDataVision
Thread Options
#2083548 - 06/15/16 04:45 PM Possible SAR for cash in SDB
ABT Offline
Junior Member
Joined: Nov 2010
Posts: 32

Should a bank file a SAR when a customer deposits over $10,000 in cash after they directly exit their Safe Deposit Box? If so, is it for the suspicion of the true source of the cash? A CTR will be filed, so the transaction will be reported in that manner.

Return to Top
BSA/AML/CIP/OFAC Forum
#2083550 - 06/15/16 04:51 PM Re: Possible SAR for cash in SDB ABT
edAudit Offline
Power Poster
edAudit
Joined: Jul 2008
Posts: 4,781
You are here
Is it illegal to have cash in the S/D box?
_________________________
Opinions can be considered as coming from anywhere but my employer.

CAMS


Return to Top
#2083555 - 06/15/16 05:06 PM Re: Possible SAR for cash in SDB ABT
Daisy Doodle Offline
Diamond Poster
Joined: Feb 2014
Posts: 1,030
Southern U.S.
To me it would depend on facts and circumstances surrounding that customer and other activity for that customer--perhaps you can look back and see where the cash withdrawal took place that filled up the safe deposit box. Also, you can see what he did with the funds after the deposit. But there is a box on the SAR for suspicion related to the source of cash, so if the branch obtained no information for you at the time of deposit, you may want to use it after you examine the situation.

Return to Top
#2083722 - 06/16/16 01:00 PM Re: Possible SAR for cash in SDB ABT
thomasj Offline
Power Poster
Joined: Mar 2001
Posts: 5,063
Pennsylvania
If it is a one time transaction, I would note the transaction in the customer's file, but not file a SAR on this one event. If the customer makes a pattern of visiting his safe deposit box and immediately depositing $10k, then I would file a SAR for structuring and note the activity with the safe deposit box. I've seen cases where the safe box was used to hold a lump sum of cash in a safe place while the owner structured the deposits to avoid currency transaction reports.
_________________________
Knowledge is knowing what to say. Wisdom is knowing when to say it.

Return to Top
#2083723 - 06/16/16 01:11 PM Re: Possible SAR for cash in SDB ABT
edAudit Offline
Power Poster
edAudit
Joined: Jul 2008
Posts: 4,781
You are here
in the example above a CTR was (or will be filed) so there would be no structure. Without a conversation with the customer you (or us) have no idea if the funds were legit or not, just that they were stored in a place where it is not illegal to be kept.
_________________________
Opinions can be considered as coming from anywhere but my employer.

CAMS


Return to Top
#2083740 - 06/16/16 02:02 PM Re: Possible SAR for cash in SDB ABT
Elwood P. Dowd Offline
10K Club
Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
From the exam Manual:

Efforts to Avoid Reporting or Recordkeeping Requirement
[redacted]
•A customer accesses a safe deposit box after completing a transaction involving a large withdrawal of currency, or accesses a safe deposit box before making currency deposits structured at or just under $10,000, to evade CTR filing requirements.


As suggested, if using the safe deposit box was an element of attempting to structure, you have the basis for a considering a SAR. That's not what you have here. All you are left to consider is whether it is suspicious that someone keeps cash in a safe deposit box. Hint, it's no more suspicious that they keep it in a safe deposit box than if they keep it under their bed.
_________________________
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
#2083773 - 06/16/16 03:39 PM Re: Possible SAR for cash in SDB ABT
thomasj Offline
Power Poster
Joined: Mar 2001
Posts: 5,063
Pennsylvania
I missed the "Over" $10,000 the first read through. Obviously, not structuring then. There is that almost urban myth perception that keeping cash in a safe deposit box is somehow illegal that makes us question ourselves when someone does transactions such as this.
_________________________
Knowledge is knowing what to say. Wisdom is knowing when to say it.

Return to Top

Moderator:  Andy_Z