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#987379 - 07/03/08 01:27 PM Large Opening Deposit - SAR?
HR Banker Offline
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Joined: Oct 2002
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We have a new customer that opened an account with a large cash deposit. We have no pattern of activity to determine this is unusual for him. He is the owner of a business. Of course we'll watch his account for anything suspicious going forward but someone is questioning whether a SAR is needed. A CTR was completed at the time of deposit. I don't see the need for a SAR but am I missing something?

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#987515 - 07/03/08 02:42 PM Re: Large Opening Deposit - SAR? HR Banker
David Dickinson Offline
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David Dickinson
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Central City, NE
Why is this suspicious? I would rate the account as high risk and monitor it appropriately - as you have indicated. With nothing else to go on, I don't believe a SAR is warranted.
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#987570 - 07/03/08 03:06 PM Re: Large Opening Deposit - SAR? David Dickinson
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Thanks David. Those were my thoughts also. Since I posted my question another employee checked with someone from a BSA seminar and their opinion was that if this is not normal for our customer base then we should consider filing.

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#988148 - 07/04/08 03:38 AM Re: Large Opening Deposit - SAR? HR Banker
rlcarey Offline
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rlcarey
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Galveston, TX
How large of a cash deposit are we talking about?? If you are talking about a "large" cash deposit to open an account, your enhanced due diligence procedures should have kicked in at account opening and some sort of verification of the source of funds should have been performed before accepting the deposit. Worrying about this after the fact is not the appropriate approach..
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#988962 - 07/07/08 06:08 PM Re: Large Opening Deposit - SAR? rlcarey
Maytagman Offline
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Joined: Jun 2008
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South
I would look at the customer's occupation as well, assuming your account opening procedures require that information be obtained. We filed a report on this exact situation when the customer deposited $35,000 cash to open the account, and stated her occupation was "elderly caregiver."
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#989081 - 07/07/08 07:38 PM Re: Large Opening Deposit - SAR? Maytagman
GenerousLife Offline
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Joined: Feb 2002
Posts: 1,466
USA
Maytagman has provided an excellent example. If his customer had stated their occupation as "fireworks stand owner", it would make more sense to have $35k in cash, but a caregiver? That would be very suspicious.
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#992511 - 07/10/08 06:20 PM Re: Large Opening Deposit - SAR? GenerousLife
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BSA officer wanted to file so he did. Customer owns a sawmill. Cash deposit was 6 figures.

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#992714 - 07/10/08 08:24 PM Re: Large Opening Deposit - SAR? HR Banker
smash Offline
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Joined: May 2004
Posts: 331
Texas

Oh my.

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#992762 - 07/10/08 08:50 PM Re: Large Opening Deposit - SAR? rlcarey
whistler Offline
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Joined: Jun 2008
Posts: 39
What would you be looking for as verification for source of funds?

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#993096 - 07/11/08 11:18 AM Re: Large Opening Deposit - SAR? whistler
Elwood P. Dowd Offline
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Next to Harvey
Putting a sharper edge on the "source of funds" issue, sometimes the choice comes down to flatly asking the customer where the money came from or filing a SAR. Personally, I would prefer to ask the question.

While SARs are oftentimes filed because the bank simply cannot figure out what's going on, the customer always knows what's going on. Asking him is just the simplest thing to do and the world doesn't need any more worthless SARs.

It's a difficult task for anyone and not one easily imposed on a 19 year old CSR. It can be done by an officer. It can be done after the fact. It can be done casually. It can be done...

If the customer refuses to explain then I've got another sentence for the SAR that I was already stuck with filing. Unfortunately, I've also got another customer for the "watch" list.
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#994607 - 07/14/08 05:39 PM Re: Large Opening Deposit - SAR? Elwood P. Dowd
CantBeShocked Offline
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Joined: Apr 2006
Posts: 260
MS
I would ask questions and then base your decision on the answers (or lack of) given by the customers.

I had a similar situation and without asking the customer questions, it was immediately questionable, BUT the funds were cash. It did not help that the cash was strapped over a period of years and stamped with many various bank's teller stamps as well as the Fed's stamps AND the individual's occupation was a "retired state trooper". The amount was well into six figures. Given the salary of state troopers (particularly here in the south) - I filed.
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