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#2269209 - 04/16/22 08:09 PM Customer paying contractors for home build in cash
J_G Offline
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Joined: Dec 2010
Posts: 259
Hi. We have a customer who is having a home built and occasionally pays his subcontractors in cash in order to get a discount. He withdraws cash ranging from $15k to $30k to them pay them, so we have filed CTRs. Originally we thought the amounts being paid to the subcontractors was also within the $15k - $30k range and that our customer was getting signed receipts, but now after another discussion with the customer we aren't so sure.

If they are getting signed receipts and the transactions aren't being structured, should we still file a SAR?

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#2269210 - 04/16/22 08:32 PM Re: Customer paying contractors for home build in cash J_G
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,227
Galveston, TX
Does he also have a loan with you or another bank or is he paying strictly cash for the house. I might be looking hard at the source of cash, then make a call whether or not you feel he is structuring cash payments. If he does have a loan, then why would a lender allow that and not control all payments to the contractor, as to ensure that no mechanic's liens are filed?
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#2269211 - 04/16/22 09:39 PM Re: Customer paying contractors for home build in cash J_G
J_G Offline
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Posts: 259
He doesn't have a loan with us. He is a doctor but the deposits on the account are primarily deposited checks from a family member that is paying our customer back for a personal loan he gave him for a portion of land...

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#2269212 - 04/17/22 02:07 PM Re: Customer paying contractors for home build in cash J_G
ACBbank Offline
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ACBbank
Joined: Jul 2006
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New York City
Edited: I just noticed your second post regarding the source of funding. What do you know about the family member writing the checks? Can they legitimately generate this type of income? Have you seen the note between the Doctor and the family member?
Last edited by ACBbank; 04/17/22 02:39 PM.
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#2269213 - 04/17/22 04:34 PM Re: Customer paying contractors for home build in cash J_G
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,227
Galveston, TX
Unless you think they are layering illegal proceeds, you think there is structuring involved, or possibly human trafficking if the contractors are employing illegal aliens, I think I would close the book on this one. I am not sure you otherwise have any obligation to investigate the relationship or business dealings among family members.
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#2269214 - 04/17/22 06:05 PM Re: Customer paying contractors for home build in cash J_G
J_G Offline
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Joined: Dec 2010
Posts: 259
The family member is also a doctor but we have not seen the note between them.

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