Used a rule in AML program that looks back 90+ days. Found a long-standing cust. got a big check in 8/07/07. During the next 30 days he cashed 6 checks for $8,000. payable to himself. All subsequent trans. typical stuff. Should I file a SAR saying trans. not typical or appear to be some kind of structuring???? Or, should I monitor for 6 months and, if no repeat, call it quits?

I would file for structuring- 6 transactions =$48,000 in 30 days. Unless the customer has an explanation of why the withdrawals were made over 30 days. In the case like this i file and in the narrative explain where the funds came from- attorney settlement checks, retirement,disability. i also document what we know about this individual, how long they've been a customer and whether or not we think they are involved in any illegal activity, other than structuring. We're a small town and sometimes we know that our customer has withdrawn the cash to simply go down the street and across the street to purchase CDs from other banks. They just don't understand banking, CTRs, IRS, etc.

Also explain in the narative why it was not noticed at the time. Hopefully this software is new and will prevent missing such transactions in the future.


Al