Skip to content
BOL Conferences
Thread Options
#2241861 - 09/01/20 02:57 PM CTR and SAR
Compliance Action Subscriber 1226 Offline
100 Club
Joined: Sep 2015
Posts: 198
We had an elderly customer come in yesterday and withdrew $20,000 in cash. Teller asked her several questions, without trying to get into her business too much, what her plans for the money was. She gave information that she was having some carpenter work done and also some medical bills. After she left, the teller, not feeling comfortable with the situation, got in touch with the customer's daughter. To make a longer story short, the customer said she was contacted by social security that someone was using her SS# and she was suppose to mail the cash, she never said where (definitely a scam). Anyway, the cash was returned to the night deposit. So, it was out one day and then returned overnight. Should we file a CTR for both withdrawing and depositing and should there be a SAR filed for the attempted scam?

Return to Top
BSA/AML/CIP/OFAC Forum
#2241864 - 09/01/20 03:37 PM Re: CTR and SAR Compliance Action Subscriber 1226
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,226
Galveston, TX
Yes on the CTRs - no on the SAR - it is under $25K without a suspect.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#2241873 - 09/01/20 05:41 PM Re: CTR and SAR Compliance Action Subscriber 1226
Compliance Action Subscriber 1226 Offline
100 Club
Joined: Sep 2015
Posts: 198
OK, thank you

Return to Top
#2241881 - 09/01/20 06:38 PM Re: CTR and SAR Compliance Action Subscriber 1226
HappyGilmore Offline
10K Club
Joined: Jun 2004
Posts: 19,844
Pulling people out of the ditc...
and you may want to check to see if your state has a mandatory reporting guideline for elder financial abuse. and certainly flag the account in case this is attempted again.
_________________________
Providing alternative truths since the invention of time

Return to Top
#2241921 - 09/02/20 01:43 PM Re: CTR and SAR HappyGilmore
InFairness, CRCM Online
Platinum Poster
InFairness, CRCM
Joined: Nov 2010
Posts: 919
USA
I'll second the recommendation for checking state elder financial exploitation laws. In my state, banks must report all attempted financial exploitation of elderly or disabled adults to Adult Protective Services and SAR filing is recommended for any attempt exceeding $5,000.

The CFPB also recommends using the SAR filing process to report elder financial exploitation in addition to making reports to LE and APS.
_________________________
Opinions are strictly my own, and have nothing to do with my employer.

Return to Top
#2242015 - 09/03/20 01:52 PM Re: CTR and SAR Compliance Action Subscriber 1226
Pat Patriot Act Offline
Gold Star
Pat Patriot Act
Joined: Apr 2009
Posts: 450
Originally Posted by Compliance Action Subscriber 1226
Should we file a CTR for both withdrawing and depositing and should there be a SAR filed for the attempted scam?


Do you need to file a SAR? Technically, not right now. But the $25,000 threshold shouldn't be used as an excuse to dismiss suspicious activity. You're supposed to be using the extended 60 day deadline to try and identify a suspect.

If you leave this as is, a knowledgeable examiner would scrutinize the completeness of your investigation. If the customer was going to mail the cash; ask her - who was this addressed to? Who are you speaking with? Have a conversation with your customer and figure out all of the details. I can almost guarantee you that such a conversation will result in you having identified a suspect. And failing to have that talk borders on willful blindness.

Talk to your customer, identify the suspect, file the SAR.
_________________________
CFE, CAMS

Return to Top

Moderator:  Andy_Z