If you had a customer who deposited $10,500 PPP proceeds check from another institution on 4/28/27 and took out $5,000 in cash and came in the next day and withdrew $5,000 in cash, would you report this? If yes, what would you report?

Those would certainly raise my eyebrows. At the very least I would be having a conversation with the customer about what sort of business they are running, why they need the cash, and how they plan on tracking expenses to ensure forgiveness.

"If you had a customer who deposited $10,500 PPP proceeds check from another institution on 4/28/27" How would you know that they are PPP funds?


"5,000 in cash and came in the next day and withdrew $5,000 in cash," I would follow normal BSA processes for this

Original Poster:
The check deposited said PPP loan.
As far a the cash withdrawals, they could have withdrawn $10,000 and it would not have been reported. Maybe they did not know they had to withdraw $10.000.01 to be reportable. Was the intent to structure?

Would you report possible PPP loan fraud because the funds were withdrawn in cash?

The cash could have been used for payroll, but not a good way to pay employees. The cash could have been back pay?

Has anyone thought just to ask your customer the what for and why this way question first?

This

Does it matter where the source is from? I don't understand why it would "raise eyebrows" because it's PPP funds.

Is it suspicious when business owner advances $5000.00 from a credit line?