We have a situation whereby a customer has a business checking account and a personal checking account. The business could receive cash or checks on a daily basis - a cleaning service. The personal account has the most activity; large deposits, outgoing wire transfers, etc. The business account has far less deposits. Does anyone think this type of situation warrants a SAR?

I wouldn't be inclined to pull the trigger on a SAR without a lot more research. Are the wires going to a suspicious OFAC-type location? Are the big deposits in cash, frequent, and close to but not over $10000? To whom are the deposited items payable - business or individual? Is this a successful cleaning business? (Quick & dirty measurement - how big is his ad in the yellow pages?) (More formal measurement - does your loan department have a financial statement?)

Obviously, there's SOMETHING making you suspicious. Can you quantify? My initial thought was that he's trying to use his personal account to circumvent less favorable business account pricing.

Bart - my first thought was tax avoidance for the business account....should we even care?...the deposits are mostly cash (into the personal account).

This is just a matter of personal preference, but I have a hard time justifying a SAR on suspicion of tax evasion. This is because I don't know how the guy is going to file his taxes. (Now, if he's a borrower & I subsequently get his tax forms, that's a different story...)

Based on the situation you describe, if it's me, I'm building an evidence file. I don't think it's a SAR yet.

I agree with Bart. You must have some reasons for your questioning of this customer's transactions. But before you label them as suspicious, do some more due diligence. Obtain a D&B or some other credit report on the business to get an estimate of the annual sales. How does he pay the bills? If by check, see if the payees are legitimate businesses? Watch the account for 30-60 days, or ask the owner himself/herself why he deposits cash into his personal account. There may be a simple answer to his activity. On the other hand, he may balk at answering any questions, which may tip your hand toward filing a SAR.

Unfortunately, in some cases there is no clear cut method of determining whether an activity is suspicious or not. However, pursue your initial instincts and follow the account closely before you make the decision to file a SAR. Remember, you have time to review the "unusual" activity. But once you determine that it is "suspicious", then you have 30 days to file the SAR.

Absolutely no! It's just like calling the police on someone, so suspect reports should be well considered with something really out of whack. If large dollar deposits are involved, reporting those dollars normally sends the appropriate level of alert.

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The personal account has the most activity; large deposits, outgoing wire transfers, etc.

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I would look at the personal account activity. Are the patterns of large deposits akin to structuring? If so, then you need to file an SAR at least for structuring. Look at the wire activity. Are the wires going outside the country? Are they going to countries known for tax havens or drug activity?

If you don't have structuring, and you don't have suspicious wire activity, then perhaps all you do for now is to keep monitoring the account.

I'm new to the security scene and was wondering what "structuring" is in regards to SARs.

Structuring is a way to arrange your deposits/withdrawals to avoid filing a CTR. This would be like depositing $9,500 in cash in two days instead of the $19,000 deposit in one day or changing your transaction to avoid the CTR filing.