We have a customer that I noticed was depositing cash over $4000 - 9600 in 100 notes on a regular basis - some sequential. He is a CPA and has other business accounts with us including a real estate business. After some research, he is a registered agent for a medical marijuana medical office. I still find all of this suspicious and when he was asked where the funds came from (New Account Profile said he would deposit $0% in cash) he said from his investors. Possible funds could be paid from the marijuana business; possible he is structuring at a minimum. Not sure which way to go with this though I find it hard not to think marijuana-related with the timing as he was a new agent for this business June 2018 and started the cash deposits August. Thoughts, please? Thanks!

We'd file a SAR for marijuana termination and close the accounts.

Termination?

Filing Suspicious Activity Reports on Marijuana-Related Businesses

“Marijuana Termination” SAR Filings

If a financial institution deems it necessary to terminate a relationship with a marijuana-related business in order to maintain an effective anti-money laundering compliance program, it should file a SAR and note in the narrative the basis for the termination. Financial institutions should use the term “MARIJUANA TERMINATION” in the narrative section. To the extent the financial institution becomes aware that the marijuana-related business seeks to move to a second financial institution, FinCEN urges the first institution to use Section 314(b) voluntary information sharing (if it qualifies) to alert the second financial institution of potential illegal activity. See Section 314(b) Fact Sheet for more information.

Source: https://www.fincen.gov/resources/statute...ated-businesses

I concur with Justin Case file a SAR for marijuana termination and close out the relationship.

Just to clarify - the Marijuana Business is not our customer. Our customer is associated with the business based on research. Would this still be a Marijuana Termination? I have recommended we close his accounts and maybe all of his other accounts as well so that he does not start depositing that cash to those accounts.

It would still be marijuana termination for us ---- I have no doubt the cash deposits are coming from the medical marijuana office. We see this all the time.

Another question - would you close immediately or send a closing letter?

What does your policy/procedures say you will do upon discovering a MRB?

As TryingtoComply said, it's dependent upon your policy and procedures. Ours specify 10 days' notice before closure.