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#2270385 - 05/12/22 05:06 PM Suspicious -Cash from Business Applied to Personal
aherbert Offline
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Joined: Sep 2016
Posts: 17
Good afternoon all,

I'm working on writing up a report for a business owner who deposited cash saved up from the business to their personal account. This customer deposited funds just below the CTR reporting threshold to the personal account, checked the balance, deposited an additional amount of cash just under the reporting threshold then checked the balance again. Clearly this appears to be an attempt of structuring...I'm also concerned about tax evasion. The customer offered up to the teller that they didn't want to show that much profit to the business. So many alarms going off in my head...

Any other reporting reasons that I should be on the lookout for?

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#2270387 - 05/12/22 05:21 PM Re: Suspicious -Cash from Business Applied to Personal aherbert
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 79,269
Galveston, TX
Nothing besides closing the accounts so this is the last occurrence you have to report.
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#2270396 - 05/12/22 07:08 PM Re: Suspicious -Cash from Business Applied to Personal aherbert
aherbert Offline
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Joined: Sep 2016
Posts: 17
I don't disagree! Thank you!

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#2270418 - 05/13/22 03:44 PM Re: Suspicious -Cash from Business Applied to Personal aherbert
edAudit Offline
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edAudit
Joined: Jul 2008
Posts: 4,771
You are here
I would think that filing a SAR would be in order since the transaction is over $5,000, you have a subject, and you suspect structing.

I would also conduct a lookback on the customers relationships to see if there is anything else.
Last edited by edAudit; 05/13/22 03:50 PM.
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