I have a customer (foriegn decent) that I have been watching for a while. He purchased cashiers checks two weeks ago for a good sum of money. Today he brought back those cashiers checks, along with a very large sum of cash to wire out. The country is not on the OFAC list, however It is really bothering me. He even mentioned that he will be leaving the country soon. What should I do? Should I call someone, I am worried. I don't want to accuse anyone but, I don't want this to slip by unnoticed. Please help me right away. Thank You

Of course if the cash is in excess of $10,000 a CTR must be filed and I would probably do the SAR, but other than that I can't think of anything. You might want to look at who the original Cashier's Checks were payable to, etc. Sorry I can't be of more help.

It might be helpful if you tell us why you have been watching him. What types of transactions has he been conducting other than the one involving the cashier's check?

Is this a business account? Are the cash transactions consistent with that type of business? If it is a personal account, sudden large sums of money might also be reason for a SAR.

It is probably too late now to have a discussion with the customer, but in the name of Knowing Your Customer (or whatever we are calling it this week) it might be good for your staff to be trained to ask customers, in a concerned way, about unusual transactions on the spot. This might help prevent a fraud against the customer or the bank.

There is really insufficient information given to determine whether a SAR should be filed. Is this a long-time customer? Is it a business or personal account? How much is a large sum of money? Who were the payees on the cashier's checks that he/she returned? Why were these checks returned? Who are the beneficiaries of the wire transfers? Where are the wire transfers going to? How many unusual transactions has this customer had? What time period is meant by "watching for a while?"

What it comes down to is your knowledge of the customer (KYC,EDD,CIP). You have been watching this customer for some time, but what was it that triggered your investigation?

It's really your decision, but make sure that you include all the facts available before you file a SAR. (Also, make sure you describe this in your SAR.)