A MSB customer withdraws $8000 usually every other day or sometimes 2 days in a row. (New account - 6 months - previous bank stopped banking MSBs.) Never has w/d over $10,000 so no CTR. Discussed with customer and he says this is the way he needs the cash based on the amount needed for cashing checks. The more I think about it, I think this is structuring. I just want to get additional opinions, please! Thank you.

The more I think about it this is the real reason why they were dumped from their prior bank.

If you bank the entire relationship you should be able to track the checks vs the cash over a short period of time.

We bank MSBs and I have not ever seen one that took regular cash withdrawals. usually larger amounts before weekends and holidays. I would recommend ECDD including a comparison of deposited checks and cash withdrawals. Also, if they are funding an ATM you want to include that in your ECDD calculations. For ECDD purposes we request the entire cash relationship.

I agree with beach, do a sample of the deposited checks within a specific timeframe and also the cash withdrawals. I would also pay attention to the frequency of deposits and their amounts and the frequency of withdrawals and amounts. I might be a synic but 8k every other day is fishy to me.

Keep fishing

So, his business apparently needs about $4,000 in cash every day. In order to avoid an allegation of structuring he needs to come in every third day and withdraw $12,000?

The decision to file the first SAR is the decision to file a series of SARs if the activity continues. This one deserves some more thought.

Devote the time you might have spent filing this SAR to changing your policy on opening accounts for MSBs. If a single MSB draws this much attention and analysis you do not want it, nor do you want any more

(New account - 6 months - previous bank stopped banking MSBs.)

All MSB's or just him???

The other Bank stopped doing MSBs period.

Compare the withdrawals with his deposits and make sure he isn't structuring his deposits also. As Ken says, once you start filing SARs you will never be able to stop.

Or, instead of filing a SAR, just close his account. These are no win situations. Most examiners my client's have been exposed to are going say this is structuring no matter what your reasoning and you are going to get cited for failure to file SARs.