We have an individual who brought in a $10K cash deposit for a business. He said that he did it as a favor because everyone at the business was unable to leave the business to go to the bank to make the deposit. We have our system settings prompt our tellers for CTR information at a certain amount so that if another cash deposit was made at another branch, we'd have both of the conductor's information. When the individual who was doing the favor was asked conductor CTR information, he became agitated and tried to pull the transaction back. He refused to provide the identification but our teller eventually talked him into doing so. He was still reluctant. His ID he provided was expired, refused to provide his own phone number, and said that "the business does this all the time so they need to take their business to another bank." He's not an owner or a signer on this business account.

My question is do you think a SAR should be filed on this scenario? Technically, he did try to pull the transaction back after he found out a CTR would be filed, but...

29C on the SAR seems to apply. But it sounds to me someone needs to talk to the business about the activity in general. Do they 'do it all the time'? $10K cash deposits?

I thought the same thing that 29C would apply.

His comment about the business making $10K cash deposits 'all the time' is incorrect as the business makes deposits that warrant a CTR filing as well (I should've included that with my first post). I don't believe there's any other structuring going on. We have one of the business owners ID on file so that when a CTR is filed and he's the conductor, we just go to that information to complete the CTR.

If all other transaction activity into the account(s) is not suspicious and it is just the reaction of this unrelated party I would be hesitant to file a SAR. If there is additional information to consider that would change my mind then I might consider filing but at the moment I wouldn't.

Sometimes people just don't like to give out all their information to an institution they don't bank at, I wouldn't want to give mine out if I was in the same situation and didn't have an understanding of CTRs etc...

It wasn't a reportable transaction. The only infraction here is related to the customer not wanting to comply with bank policy.