#2174061 - 04/18/18 04:33 PM
Overzealous BSA Examiner - Help Needed
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Anonymous
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First-time BSA examiner at our financial institution is dropping this in our laps at the end of the exam:
If a customer purchases a large cashier's check (say, $20,000) and doesn't ever cash it, that's suspicious. Where's your SAR? What is the "purpose" of storing money in a monetary instrument, rather than depositing them into an account?
Customer purchased an $8900 check 5 years ago, came in last month and turned it into $1,500 cash, and a $500 check to IRS, and a new cashier's check for $6900. This is "check churning." Where's your SAR?
Customer made a deposit 2 years ago, containing a cashier's check for $150,000. That cashier's check was 8 months old when it was deposited. What was the business or apparent lawful purpose for "storing the money" in a monetary instrument? Where's your SAR?
Customer closed out her $75,000 CD a year ago and never cashed the check. Why is the check still outstanding? Where's your SAR?
At this point, they are talking citing the bank for failures in training, internal controls, and failure to file reports. You know where that leads.
How would you reply?
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