Skip to content
BOL Conferences
Thread Options
#983188 - 06/26/08 06:57 PM Business cashing payroll checks with a twist...
devsfan Offline
Diamond Poster
Joined: Jun 2004
Posts: 1,927
NYC
Here is a new one: payroll checks that were cashed for employees of a business are being deposited to the personal account of the business owner instead of the business account. Would you file a SAR for un-registered MSB check cashing activity?

Return to Top
BSA/AML/CIP/OFAC Forum
#983246 - 06/26/08 07:29 PM Re: Business cashing payroll checks with a twist... devsfan
Maytagman Offline
Gold Star
Maytagman
Joined: Jun 2008
Posts: 285
South
I don't buy the MSB thing. The business is not an MSB if it cashes its own payroll checks. It doesn't make sense that they would be deposited into the owner's account, though, but that probably has more to do with tax evasion than MSB activity.
_________________________
"It is natural to give a clear view of the world after accepting the idea that it must be clear." - Albert Camus

Return to Top
#983652 - 06/27/08 12:50 PM Re: Business cashing payroll checks with a twist... Maytagman
devsfan Offline
Diamond Poster
Joined: Jun 2004
Posts: 1,927
NYC
So, if I disregard the MSB issue since I will assume that the business is the one cashing the checks for the employees, I cannot disregard the fact that they are being deposited to the owner's personal account instead of the business account, and want to file a SAR for activity that has no apparent legitimate purpose. Does anyone disagree?

Return to Top
#983759 - 06/27/08 02:01 PM Re: Business cashing payroll checks with a twist... devsfan
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
I wholeheartedly agree with a SAR filing, if you believe what the customer is doing is suspicious or cannot be explained as a legitimate business transaction.

You don't have to believe the customer is doing something illegitimate or illegal to do a SAR. You only have to believe that what the customer is doing has no reasonable explanation or legitimate business purpose.
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top

Moderator:  Andy_Z