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#2154115 - 11/17/17 08:03 PM Large Cash Withdrawal
Anonymous
Unregistered

If you have a customer who requests to take $225,000 from their account and did not provide a reason for the withdrawal, would you file a SAR? I know we would need to file a CTR. When cash is requested, we ask if we could issue them a check, wire or etc. We also try to ask if they are falling victim to a scam.

One individual said he was going to move and wanted this money in cash.

We also had an owner of a DBA request a similar amount, but she did not say what the funds would be used for.

If you would file a SAR, would you mark transaction with no apparent economic, business or lawful purpose?

Any other advice?

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#2154138 - 11/17/17 09:25 PM Re: Large Cash Withdrawal Anonymous
Richard Insley Offline
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Richard Insley
Joined: Oct 2000
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Toano, VA
What crime do you suspect?
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#2154151 - 11/17/17 10:16 PM Re: Large Cash Withdrawal Richard Insley
Cape Codder Offline
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Did you ask for an explanation?
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#2154171 - 11/18/17 04:32 AM Re: Large Cash Withdrawal Anonymous
JacF Offline

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PA
If the funds on deposit came from a verifiable legitimate source, there was no attempt to structure, and no indication of fraud against the accountholder, I would note my decision to not file and move on.

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#2154180 - 11/20/17 04:01 AM Re: Large Cash Withdrawal Anonymous
Anonymous
Unregistered

What if she said it was an investment with guaranteed return and we think she maybe taken advantage of? What legitimate investment would require this much cash? Are we obligated to give the cash?

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#2154199 - 11/20/17 02:18 PM Re: Large Cash Withdrawal Anonymous
ACBbank Offline
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New York City
If it's an investment ask for the contract of sale or other relevant documentation. An investment of this size, if it's legitimate, should have some kind of documentation. I'm not sure you can deny someone their money, but I'll defer to others on this matter. However, you can absolutely tell the customer that you will need a few days to prepare that much cash. Something like this our legal counsel would require the customer to execute a release advising them that the Bank warned them against taking that much cash due to various risks involved.
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#2154207 - 11/20/17 02:44 PM Re: Large Cash Withdrawal Anonymous
edAudit Offline
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In this day and age the release would not be worth the paper that it is written on. The customers lawyer will claim that since you gave him the release you know that taking the cash was risky.

It is a no win.
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#2154233 - 11/20/17 03:56 PM Re: Large Cash Withdrawal Anonymous
ACBbank Offline
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New York City
Our Counsel would disagree Ed. I'm not an attorney, but the idea being that the client has a right to their money and other than advising them that's it a bad idea, we cannot deny them their money. Could they sue? Of course. Any one can sue any one. Whether or not they win is a different topic all together.
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#2154299 - 11/20/17 07:49 PM Re: Large Cash Withdrawal Anonymous
JacF Offline

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ACB-

I don't think Ed was advising against giving the customer their cash. I think he was opining that the release for you describe would probably do nothing to protect the bank.

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#2154493 - 11/21/17 09:40 PM Re: Large Cash Withdrawal Anonymous
Anonymous
Unregistered

Many more questions to ask before determining if the withdrawal is SAR worthy...
What is the customer's average account balance?
What is the age of customer? is the customer retiring and going south ? Maybe customer is buying a second home down south? Maybe you could suggest a safer alternative that cash ?
What location of the country are you located? Is there a good economy there?
Has the customer had a well paying job ? Where have his deposits come from overtime ?
The large withdrawal discussed is not unusual where I come from. Good economy, lots of quickly made (5 years) money, and no where to spend it. Large amounts of cash are pulled to take 'back home' when the job is over, or they have had enough.

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#2154538 - 11/22/17 02:11 PM Re: Large Cash Withdrawal Anonymous
ACBbank Offline
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ACBbank
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New York City
Jac - I get that. Our in house attorney drafted a fairly strong release in an attempt to protect the Bank. We've been through this before and management believes the release is worth having.
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"100 victories in 100 battles isnt the most skillful. Subduing the other's military w/o battle is the most skillful." Sun-Tzu

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#2154973 - 11/28/17 04:32 AM Re: Large Cash Withdrawal Anonymous
SMQ, CRCM Offline
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Between the lines
I agree with the release. Will it totally protect you in court, maybe not. But when the kids come in and want to blame the bank for not protecting dear ole mom or dad, at least you can prove that you tried to do just that.
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#2154995 - 11/28/17 01:54 PM Re: Large Cash Withdrawal Anonymous
edAudit Offline
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When the precious kids come into the bank they need to know that they have no rights to the money (if not on the account) and no rights to get any information on moms account. Otherwise you will be going around in a circle with them for years on this and every other perceived issue. (been there)

But if the release gives the bank some comfort level go for it just do not bank on it holding up in court.
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