Here's our situation...

We have a customer of the bank wiring somewhat unusually large amounts of cash (for them) out. This is a personal account.

This customer is employed by another customer of the bank, a business. And this other customer of the bank typically has large deposits of cash.

We're now to the point that we're filing a SAR... this employer of the customer is a county office... we have a fear that our customer is taking money from our other customer and wiring out, but that's just speculation, at this point. Does anyone know of anything else we should be doing? I'm not sure we have enough to report to local authorities or anyone else. We have an unsubstantiated idea... some odd activity... and the privacy of both customers that we need to protect.

Just wondering what others might think of this!

Thank you.

I'm sure you may have done this, but have you looked to see if cash deposits have decreased in the employers accounts about the same time the wires started going out?

IMO, unless you have some hard data to tie these together (such as noting a trend mentioned above) I would stay away from fleshing out your theory in a SAR. On the other hand you don't have to be judge and jury of what is happening, if you suspect something unusual then file a SAR for exactly that reason. I have filed for a customer doing something out of the norm for his/her account, but I let the powers that be draw the conclusion.

What does the customer say the purpose of the wire transfers is/are (not all the caffeine has taken effect, sorry)? If the amounts are out of character for the customer, are the wire benes also out of character? (Has he 'bought' a D10 Cat, for example?)

Our bank requires that when a customer sends a large wire for the business or personal matter, the customer must provide the purpose of a wire. And if the business account holder has large deposits of cash, you might want to know whether the sources of funds are legitimated or not. If the business is cash intensive and has large volume of currency transactions, the bank should conduct EDD and a site visitation for the documentation of the subject business account.

I agree with notuntermywatch. If you are concerned with the activity, in the SAR filing state the facts and leave your opinions out of it.

This has been a tough situation for us. We know enough about our customer's personal issues, as well as a couple other things, that I think it has led us to suspect the possibility of embezzlement from their employer, the county office. However, it would look pretty bad to go around accusing someone of something like that when it could very well not even be the case.

It seems like there's really no good way, either, to talk to our other customer, the county office, without jeopardizing the privacy of our personal customer... when, in fact, their activity may have nothing at all to do with their employer.

We have enough grounds for the SAR based on the wire activity, so I think that's what we'll do and leave it at that.