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#2139163 - 07/21/17 09:51 PM Customer Leases Equipment to MRB
TryingtoComply Offline
Diamond Poster
Joined: Apr 2013
Posts: 1,980
The West
We recently discovered a customer that leases equipment to a marijuana-related business. We have terminated the relationship.

In reviewing the activity I see one wire received from the MRB and several outgoing wires to the MRB. What should I report as the dollar amount for my SAR?

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#2139165 - 07/21/17 10:35 PM Re: Customer Leases Equipment to MRB TryingtoComply
Midwest BSA Offline
Joined: Sep 2014
Posts: 54
If those are the only obvious MRB transactions, I'd probably just use those and explain your reasoning. I think the point of your particular SAR is more about the fact that they were doing business with a MRB that you weren't aware of - so you're calling those wires into question. Unless you're questioning their business practices in general...and a tip for you (we're in a marijuana state too) - do some Google research and pull up their license on the state's website. Oftentimes, the dispensary is a DBA - so there could be more wires out there under a parent name. Good luck.

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