Based on some of these posts I'm not sure how long @MBOC has been working in AML or if he/she actually does. There seems to be a lack of understanding of basic AML investigative techniques.
That or it's someone trolling.
I didn't create an account at BO so I could troll. Been in BSA for 20yrs at this point, from AML customer investigations to internal audit to internal employee AML investigations. I came here mostly to ask questions re:CTRs because that's a new realm for me having oversight of it now. But I guess since I haven't been around for 40yrs or 39yrs, feel free to dismiss me.
My point is that BSA is about compliance. The reg req't is to file a SAR, not interrogate your customer about every single transaction they do. Like I said to OP, you could ask 100 people about a case and get 100 different opinions/thoughts because everyone's experience with finances and money and business and industry and knowledge is different. What's exorbitant money to one investigator may be pennies to another. Every alert that generates there's tons of unknowns......incalculable really.....so in order to clear them do you reach out to every customer and have them explain it? Whether that customer is legit or a bad guy, you're getting story A. You think you're going to call a bad guy and he's going to say -- 'Aw shucks! Ya got me. Yeah I work for a cartel in my free time and I was trying to be crafty working as a carpenter, but you caught me. Had you not called me I would have never gotten caught!"
I've never exited/closed a customer because they're "money losing" or because we file SARs on them. Are folks here actually as a part of their investigation(s) analyzing a relationship's profitability before they file a SAR?
I'd love to know from FinCEN how many SARs get filed annually that never get touched or read or accessed. BSA compliance is a huge time/resource suck, file SARs on stuff that is completely unreasonable and suspicious. A contractor doing $250k in transactions per year is nothing where I'm at, likely wouldn't even hit our alert rules.
All good though, have at it. I'll stay out of it from here on.