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#2160088 - 01/11/18 02:52 PM SAR-Which boxes to mark?
Complycated Offline
100 Club
Joined: Aug 2013
Posts: 165
We had a customer ask a lot of silly questions about how to best structure his transactions to avoid any reports being filed with the government. We provided him with the FinCEN pamphlet and sent him on his way. Two days later he went to a different branch and deposited $9,800.00 in cash. Obviously we have to file on this, but I am hung up on which boxes to check on the SAR. Under 29, Structuring, I will mark 'f' for the suspicious inquiry but what else should be marked? He didn't alter or cancel a transaction at the window and there haven't been multiple suspicious transactions, just the one. But he clearly structured the transaction on his own to avoid reporting. Any opinions on what to mark?

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#2160248 - 01/11/18 09:25 PM Re: SAR-Which boxes to mark? Complycated
Cape Codder Offline
Gold Star
Joined: Jul 2011
Posts: 413
I'd check box Z and enter "single transaction below CTR threshold".
Nothing difficult is ever easy.

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#2160260 - 01/11/18 10:03 PM Re: SAR-Which boxes to mark? Complycated
Daisy Doodle Offline
Diamond Poster
Joined: Feb 2014
Posts: 1,030
Southern U.S.
I would check 'b' myself. I don't interpret 'alters' to mean only in the moment at the teller window, but more broadly to mean he deliberately chose an amount below CTR threshold after he asked his silly questions.

I would also mark the 'corroborating statement' dropdown and explain in the narrative.

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