For those more experienced people out there.........We have a customer that opened and account in her and her brother's name. She begin bringing in checks made payable to someone not on the account. When we told her we would not be able to take them on deposit she told us this was her husband. We told her it did not matter, she needed to bring him in and have him added to the account, and then we would have no problem. She said he could not be added to the account because he had no social security number. She is of foreign descent and I assume her husband is as well, but how he is working in the US and not having a social number I do not know. She told us she could cash the checks somewhere, and she is now bringing in large cash deposits ($7,000 and $8,000). Does anyone out there think this is a reportable event????? Any thoughts?????

I would report it, especially if the cash deposits are close together (every few days, etc.). But, regardless of the frequency, you have a customer depositing cash under suspicious circumstances.

For example: Do you know where the money comes from? No. You assume it's her husband's pay, but do you even know if she has a husband? Even if you do know her husband, what does he do to make that kind of money?

Too many questions, too few answers. File the SAR and monitor the account.

The checks she has brought in are from home builders where they are paying him for brick work. We have seen several checks from various different people who appear to be in the construction business (i.e. Jullina & Co Builders, Merritt and Son Construction). Do you still feel like I should file the SAR????

I would monitor the account for a month and analyze that information. Although you have seen these checks, you do not know where the cash is coming from. The husband is not your customer and his lack of SS# is a non-issue unless you choose to have him for a customer. It all comes down to knowing your customer. How comfortable is the branch manager with these individuals? You should have monitoring process in effect for accounts that you feel funny about. Our BSA specialist looks at about 15-20 accounts per day and tracks their activity. The security officer takes a look monthly and decides whether a SAR is necessary. If we see frequent transactions below $10,000 for an account (we have a report that shows us cash deposits in excess of $7000 daily) we record that information in order to see a pattern. We will question the Branch manager to see what knowledge they have of the activity. If they appear to be putting in $7500 a day to avoid reporting, then we file a SAR.

Thanks for the advice!!!

Have you reviewed the account activity? What is happenng to the $$ after deposited? Check for wire transfers and check the payees and amounts on the checks paid off of the account.

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Passport, BCC card, any other forms of identity to add him?? Did she just not want him on the account? He has to have some sort of identification.

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