We have an individual customer who has been a customer since 2018. He recently opened an IRA account and funded it with $5,000 in cash. Then, the following month, he had a few other cash deposits (doesn't necessarily appear structured). He works for an organization that prevents substance abuse by connecting and uniting individuals, organizations and institutions, etc so that is his occupation type.

This prompted our monitoring program to generate an alert, so then I reviewed previous months activity. He seems to regularly deposit cash in amounts between $1,000 - $5,000.

Would you consider this unusual and file a SAR?

If in your conversation with the customer there is no reasonable source for the cash then I would consider filing. At this point I don't believe you have enough information.

I'm not sure what the frequency of "regularly deposit" is but I would be interested in any retail customer who deposits more $3,000 on a consistent basis. Post taxes that would be a pretty decent salary and I would be inquiring about the source of funds.

I'd certainly open a case to track it, and depending on the investigation I might file a SAR. But usually in these cases I prefer to have someone speak to the customer first to make sure there isn't something to explain it first, unless the total cash numbers are off the charts. If it is regular cash deposits every month we have sometimes found a suitable explanation to avoid a SAR. Sometimes the customer is counseled on other deposit methods (for example, if it is said to be a transfer from another institution or the proceeds of cashed payroll checks we instruct the customer to deposit checks or ACH going forward). If it is rent we might ask for leases and then review the rent amounts and locations to see if it is in an area with a higher propensity for people to pay in cash.

It also depends on what the offsets are -- if the cash was going straight to virtual currency purchases or international transactions I would be much quicker to consider a SAR.