I have a customer who has started randomly depositing cash into their savings account. Under $5000 each time, and random times, so I'm not sure it would be considered structuring. Both owners have direct deposit from a regular job so I can't be sure where the cash is coming from.

How far apart is "random"? I will say, all of the guidance I've heard says that you'll rarely get in trouble for filing a SAR that wasn't necessary, but you can certainly get in trouble for not filing one when you should've. I'm sure others will chime in with more specific opinions than me though

Anyone that is randomly depositing $5000 into their saving account may not bee structuring, but it is definitely "Suspicion concerning the source of funds"

Maybe they're moving money from other financial institutions or selling valuables like jewelry, boats, cars, etc. Has anyone asked them what's going on?

The first two deposits were within a week, then skip a couple weeks and one more, then another week one more. I don't feel like these particular customers would even know to structure but since it's been brought to my attention I have to document it.

Maybe gambling?

Only one option to not file in my book, since as it stands these deposits are both out of pattern and from an unknown source, and that is the ask them what is going on.

You need to ask the client to explain the transactions.

agreed, don't ask us, ask the customer. it could be something as simple as they are selling off personal items (car, boat, motorcycle, etc), maybe they've been stockpiling cash at home and have decided to start putting it in the bank, they could have had investments they cashed, or they could be the next Bonnie and Clyde. only way to know is to ask them.

And after you ask them, document what you find out so you can support the decision you made. You'd hate to have a fuzzy memory in a year and have an examiner ask why you didn't file since the situation does look odd.

This post makes me think about all the needless SARs that are filed on a yearly basis because banks haven't trained their tellers or operations staff to ASK QUESTIONS. This is critical to running an effective BSA program. We are expected to know our customers. That means talking to them about transactions that are out of pattern.

Most of the time there is a reasonable explanation for what we are seeing. I rather make branch staff call the customer and get the information I need to make an informed decision than file a SAR and then have to do a supplemental review 90 days later.

I don't mean to be disrespectful to the OP, but HappyGilmore is right. Don't ask us. Ask your customer.

This is an excellent point. Not only do you need information to make the SAR determination, but depending on the answers, you also want to counsel the customer about security risks and the possibility of fraud. You also want to train staff how to respond to certain customer questions in ways that don't amount to assistance with structuring.

And even when you do train staff, some of them are so stuck in their ways they refuse to ask.

I'd have a CSR or manager call the customer and ask what's going on.

Maybe they need another job. Sorry, but this is the way it is these days.

Thank you all for your responses...they're all very helpful. Yes, more training is the answer.