We are a small savings bank. We do not offer checking accounts. We only have passbook savings account and CDs. My question is on an indivdual account (not in any way related to a business) if a new or current customer comes in to deposit $5000 in cash or more but under $10,000, do you see an obligation for us to file a SAR? It seems unusual to me now of days for anyone to carry around $5000 in cash (unless they are in busienss) but maybe I'm being too suspicious. If not, at what point would you consider SAR reporting necessary?

There would be little justification and benefit to law enforcement to file a SAR on 1 cash deposit of $5,000. You need to look into what you know about the customer, such as occupation, account history, what other activity in and out of the account is happening, etc to determine if the activity is suspicious. You might want to begin to monitor the activity more closely for a while to see if more cash is deposited or where the $$ is going. If all else fails, strike up a conversation with the customer next time you see him and try to find out more about the source of the cash.

Keep monitoring the transactions in the account, make your decision after at least more than one occurrance. You should be able to explain why you think the behavior justifies your filing of a SAR. Just because you don't think that anyone should have 5000.00 in cash isn't necessarily a good reason to file a SAR. That's my opinion though.

I agree. One occurrence is not enough to trigger a filing unless the customer happens to tell you they are avoiding IRS reporting (it happens.)

I would agree with the other opinions offered. If I filed a SAR on every $5,000 or more cash transaction I wouldn't have time for anything else... I wouldn't even have time to file all of the SARs that would be necessary. I think a lot also depends on your location. In my neck of the woods customers depositing this much in cash is hardly unusual. Like devsfan said a lot depends on knowing your customer - what do they do for a living, what types of balances do they keep, how long have they been a customer, all of this should be considedered when making the decision to file a SAR.