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#2255765 - 06/22/21 08:49 PM Re: Suspicious Activity Question Comply Central
ACBbank Offline
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ACBbank
Joined: Jul 2006
Posts: 3,950
New York City
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.
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"100 victories in 100 battles isnt the most skillful. Subduing the other's military w/o battle is the most skillful." Sun-Tzu

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#2255818 - 06/23/21 06:05 PM Re: Suspicious Activity Question ACBbank
CI@MBOC Offline
Junior Member
Joined: Apr 2021
Posts: 42
Originally Posted by ACBbank
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.

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#2255875 - 06/23/21 09:59 PM Re: Suspicious Activity Question Comply Central
ACBbank Offline
Power Poster
ACBbank
Joined: Jul 2006
Posts: 3,950
New York City
If $250,000 in cash doesn't generate some kind of alert to review, you may have bigger problems than you realize. Unless this is a really unique example I can't see how that amount of cash, through a personal account no less, shouldn't generate some kind of alert.

I also think your example is inaccurate. Are there some cases where people will view what is suspicious differently? Absolutely. However, there are also other cases where the majority of reasonable and experienced AML professionals will agree that the activity warrants a SAR to be filed.

That's what happening here. You have different posters with different training, education, experiences, and most of us are indicating that something could be suspicious here and further due diligence is required.

I could say more but I'm not sure it would be helpful to the discussion.
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"100 victories in 100 battles isnt the most skillful. Subduing the other's military w/o battle is the most skillful." Sun-Tzu

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#2256239 - 07/01/21 08:49 PM Re: Suspicious Activity Question rlcarey
Lindsay H Offline
Junior Member
Joined: Mar 2012
Posts: 34
Maybe I've missed it through the thread. I think an important question to include is - are the checks being cashed drawn on the same bank they are cashed at. Is it a customer cashing a non-customer check or a customer cashing a customer check (and avoiding fees by being a low dollar deposit customer)

There is always the added risk in building that the builder has cash flow problems and contractors cash the checks and deposit at their primary bank to avoid returned items. We've had builders suddenly go bankrupt leaving contractors with bounced checks. He may have been burned previously.

Ultimately - I agree with your previous post. Each investigator is going to look at it differently and have a bunch of opinions. No harm in asking a few additional question and at the end of the day just be ready to defend your position.

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