Customer deposits 5k in cash twice in one week- different days.

Customer writes two checks out to two different people for 5k the next day.

Checks clear. Along with other activity in account we decided to file a SAR.

My question is would the total of those two transactions be 10k or 20k? FYI- I have changed amounts for forum.

Unless there was something suspicious about the checks out, it would be the structured cash I would be worried about. I would file on $10K and describe the payments in the narrative.

Thanks Daisy- we do not know much about the payments. Unusual activity for this customer.

Nothing you can glean online about the recipients of the payments? Are they professionals of some kind in your area, or customers of your bank? Did the checks clear locally? Are they Facebook friends with your customer?

I wouldn't spend too much time agonizing about it. If you feel suspicious about the payments, include them.

No, they really appear very random. Doesn't appear to be family, not local- cashed across the US.

That's a bit more suspicious. Include them.

Thanks Daisy!

All of these transactions could be totally innocent, but if I tried to set up a subtle laundering scheme, this could be it! The checks to apparently random payees in unrelated locations could be a part of the "churning" stage of the laundering cycle. No obvious concerns on the face of it, but what if another bank (located elsewhere in the U.S. and unrelated to anything you know) makes the same borderline call and files another SAR with any facts matching yours? Bingo! The tide goes out and there, exposed for investigators, is a network of players passing money around for the sole purpose of obscuring the true origin and ownership.

I was thinking funnel account as a worst case scenario (barring terrorism!).

To your original question - should you list 10k or 20k - if you consider all of the transactions suspicious, they ALL must be included in the total. So, 20k it is.

Some folks will tell you that in a kiting case, for example, you'll only report one side so that you don't "double dip." IMHO, that's pure rubbish. But I've been doing AML for too long and have learned to accept that there are certain gray areas where knowledgeable people can disagree in good faith. One of those is what should be included in the SAR total. So long as you describe in the narrative what you're defining as "suspicious" vs. what you've simply mentioned to provide context, and that definition is within reason, you won't be subject to any issues with a knowledgeable and reasonable examiner or auditor.

Thanks all!

Did you close the account?

It depends on the situation. For some stuff we close immediately, for others we review after the 2nd or 3rd SAR. You should have some sort of guidance for this in your policy.

Account was charged off...no other activity since then.

The account was charged off?? How long was it open and why was there a charge off - seems to me there is a lot more to this story than debating the $10 - $20K reporting issue.