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#2242999 - 09/23/20 07:01 PM SAR Structuring
Web Offline
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I have a customer that made three cash deposits over the course of 4 days that total $12,000. The customer has never had cash activity before but it showed up as a potential structuring. Do I have to file a SAR since the activity exceeds $5K and could be structuring or can monitor and if there is ever a transaction again that warrants structuring file?

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#2243000 - 09/23/20 07:42 PM Re: SAR Structuring Web
Skittles Offline
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TN
Did anyone ask the customer the source of the cash deposits?
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#2243001 - 09/23/20 07:45 PM Re: SAR Structuring Web
ColoradoAML Offline
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You don't have to file if you don't believe it's suspicious, but you choose not to file, you need to clearly document why you're not filing for examiners.

We have procedures to clear one-time events in situations which are borderline but the analyst does not believe to be intentional, and when the customer has no history of similar activity. If it happens again, we'd go back and see if we should reconsider the first event. Our examiners have been fine with this.

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#2243004 - 09/23/20 08:31 PM Re: SAR Structuring ColoradoAML
Web Offline
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Joined: May 2005
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Thank you this is a great approach!

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